Download:
pdf |
pdfOMB No. 3117‐0016/USITC No. 19‐1‐4109; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)
U.S. PRODUCERS’ QUESTIONNAIRE
CRYSTALLINE SILICON PHOTOVOLTAIC CELLS
(WHETHER OR NOT PARTIALLY OR FULLY ASSEMBLED INTO OTHER PRODUCTS)
This questionnaire must be received by the Commission by October 4, 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 investigation No. TA‐201‐75 (Monitoring), Crystalline Silicon Photovoltaic (“CSPV”) Cells (Whether or
Not Partially or Fully Assembled Into Other Products)(“CSPV Products”): Monitoring Developments in the Domestic
Industry, under section 204 of the Trade Act of 1974 (19 U.S.C. § 2254). The information requested in the questionnaire
is needed to supplement data available to the Commission from other sources and is requested under the authority of
section 204 of the Tariff Act of 1974. 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)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced CSPV cells or assembled CSPV cells (partially or fully) into other products (e.g.,
laminates, panels, modules) as defined on the next five pages at any time since January 1, 2016?
NO
YES (Complete all parts of the questionnaire, and return the entire questionnaire 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: CSPV)
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, reviews, or
general fact finding investigations 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
Phone:
Signature
Email address
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 2
PART I.—GENERAL INFORMATION
Background. On January 23, 2018, the President, pursuant to section 203 of the Trade Act of 1974,
issued Proclamation 9693, imposing a safeguard measure on imports of CSPV products, in the form of
(a) a tariff‐rate quota on imports of CSPV (or “solar”) cells not partially or fully assembled into other
products and (b) an increase in duties on imports of CSPV modules. The proclamation was published in
the Federal Register on January 25, 2018 (83 Fed. Reg. 3541). The measure took effect on February 7,
2018, for a period of four years, or through February 7, 2022. Section 204(a) of the Act requires the
Commission to submit a report to the President and Congress on its monitoring of industry
developments at the midpoint of the initial period of relief, including the progress and specific efforts
made by workers and firms in the domestic industry to make a positive adjustment to import
competition. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/title_7/2019/crystalline_silicon_photovoltaic_cells_whether_or/s
afeguard.htm
Crystalline Silicon Photovoltaic (“CSPV”) Cells (Whether or Not Partially or Fully Assembled Into Other
Products) (“CSPV products”).‐‐The articles covered by the investigation are 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 investigation covers crystalline silicon photovoltaic cells of a thickness equal to or greater than 20
micrometers, having a p/n junction (or variant thereof) 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.
Included in the scope of the investigation are photovoltaic cells that contain crystalline silicon in addition
to other photovoltaic materials. This includes, but is not limited to, passivated emitter rear contact
(“PERC”) cells, heterojunction with intrinsic thin‐layer (“HIT”) cells, and other so‐called “hybrid” cells.
Articles under consideration may be described at the time of importation as components for final
finished products that are assembled after importation, including, but not limited to, modules,
laminates, panels, and building‐integrated materials.
Excluded from the investigation are CSPV cells, whether or not partially or fully assembled into other
products, if the CSPV cells were manufactured in the United States.
Also excluded from the investigation 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 investigation are CSPV cells, not exceeding 10,000mm2 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 CSPV cell. Where more than
one CSPV 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 CSPV cells that are integrated into the consumer
good.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 3
For Customs purposes, the CSPV cells covered by the investigation are provided for under Harmonized
Tariff Schedule of the United States (“HTSUS”) subheading 8541.40.60. Inverters or batteries with CSPV
cells attached can be imported under HTSUS subheadings 8501.61.00 and 8507.20.80, respectively. In
addition, CSPV cells covered by the investigation may also be classifiable as DC generators of
subheadings 8501.31.80 and 8501.32.60, when such generators are imported with CSPV cells attached.
While HTSUS provisions are provided for convenience, the written description of the scope is
dispositive.1
Included in the overall data collection in this questionnaire are certain excluded items (i.e., “low
wattage” modules) listed in the Presidential Proclamation (83 Fed. Reg. 3541, January 25, 2018)
and other excluded items listed in the September 19, 2018 and June 13, 2019 Federal Register
notices (83 Fed. Reg. 47393 and 84 Fed. Reg. 27684), although certain data concerning these items
are requested separately (see listings and definitions below for “bifacial,” “flexible fiberglass,”
“light directing film,” “Modules incorporating rear contact cells with tin‐coated solid copper
fingers,” “Rear contact cells with tin‐coated solid copper fingers,” and “low wattage”).
Presidential Proclamation 9693 excluded the following “low wattage” products from application of the
safeguard measure, which took effect on February 7, 2018 (83 Fed. Reg. 3541, January 25, 2018):
• 10 to 60 watt, inclusive, rectangular solar panels, where the panels have the following
characteristics: (A) Length of 250 mm or more but not over 482 mm or width of 400 mm or
more but not over 635 mm, and (B) surface area of 1000 cm2 or more but not over 3,061 cm2,
provided that no such panel with those characteristics shall contain an internal battery or
external computer peripheral ports at the time of entry.
• 1 watt solar panels incorporated into nightlights that use rechargeable batteries and have the
following dimensions: 58 mm or more but not over 64 mm by 126 mm or more but not over 140
mm.
• 2 watt solar panels incorporated into daylight dimmers that may use rechargeable batteries,
such panels with the following dimensions: 75 mm or more but not over 82 mm by 139 mm or
more but not over 143 mm.
• Off‐grid and portable CSPV panels, whether in a foldable case or in rigid form containing a
glass cover, where the panels have the following characteristics: (a) A total power output of 100
watts or less per panel; (b) a maximum surface area of 8,000 cm2 per panel; (c) does not include
a built‐in inverter; and where the panels have glass covers, such panels must be in individual
retail packaging (in this context, retail packaging typically includes graphics, the product name,
its description and/or features, and foam for transport).
• 3.19 watt or less solar panels, each with length of 75 mm or more but not over 266 mm and
width of 46 mm or more but not over 127 mm, with surface area of 338 cm2 or less, 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 edge, provided that no such panel shall contain an internal battery
or external computer peripheral ports.
• 27.1 watt or less solar panels, each with surface area less than 3,000 cm2 and coated across
the entire surface with a polyurethane doming resin, the foregoing joined to a battery charging
and maintaining unit, such unit which is an acrylonitrile butadiene styrene (ABS) box that
incorporates a light emitting diode (LED) by coated wires that include a connector to permit the
incorporation of an extension cable.
1
CSPV products covered by the scope are currently subject to tariff‐rate quotas under a safeguard measure
imposed effective February 7, 2018, under subheadings 9903.45.21 and 9903.45.22 (CSPV cells) and 9903.45.25
(CSPV modules) and related legal notes.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 4
The following additional CSPV products entered, or withdrawn from a warehouse for consumption,
on or after 12:01 a.m., EST, on September 19, 2018 are also excluded from the safeguard measure
(83 Fed. Reg. 47393, September 19, 2018):
• off‐grid, 45 watt or less solar panels, each with length not exceeding 950 mm and width of
100 mm or more but not over 255 mm, with a surface area of 2,500 cm2 or less, with a pressure‐
laminated tempered glass cover at the time of entry but not a frame, electrical cables or
connectors, or an internal battery.
• 4 watt or less solar panels, each with a length or diameter of 70 mm or more but not over 235
mm, with a surface area not exceeding 539 cm2, and not exceeding 16 volts, provided that no
such panel with these characteristics shall contain an internal battery or external computer
peripheral ports at the time of entry.
• solar panels with a maximum rated power of equal to or less than 60 watts, having the
following characteristics, provided that no such panel with those characteristics shall contain an
internal battery or external computer peripheral ports at the time of entry: (A) Length of not
more than 482 mm and width of not more than 635 mm or (B) a total surface area not
exceeding 3,061 cm2.
• flexible and semi‐flexible off‐grid solar panels designed for use with motor vehicles and boats,
where the panels range in rated wattage from 10 to 120 watts, inclusive.
• frameless solar panels in a color other than black or blue with a total power output of 90 watts
or less where the panels have a uniform surface without visible solar cells or busbars.
• solar cells with a maximum rated power between 3.4 and 6.7 watts, inclusive, having the
following characteristics: (A) A cell surface area between 154 cm2 and 260 cm2, inclusive, (B) no
visible busbars or gridlines on the front of the cell, and (C) more than 100 interdigitated fingers
of tin‐coated solid copper adhered to the back of the cell, with the copper portion of the metal
fingers having a thickness of greater than 0.01 mm.
• solar panels with a maximum rated power between 320 and 500 watts, inclusive, having the
following characteristics: (A) Length between 1,556 mm and 2,070 mm inclusive, and width
between 1,014 mm and 1,075 mm, inclusive, (B) where the solar cells comprising the panel have
no visible busbars or gridlines on the front of the cells, and (C) the solar cells comprising the
panel have more than 100 interdigitated fingers of tin‐coated solid copper adhered to the back
of the cells, with the copper portion of the metal fingers having thickness greater than 0.01 mm.
• modules incorporating only CSPV cells that are products of the United States and not
incorporating any CSPV cells that are the product of any other country.
The following additional CSPV products entered, or withdrawn from a warehouse for consumption, on
or after 12:01 a.m., EST, on June 13, 2019 are also excluded from the safeguard measure (84 Fed. Reg.
27684, June 13 19, 2019):
• bifacial solar panels that absorb light and generate electricity on each side of the panel and
that consist of only bifacial solar cells that absorb light and generate electricity on each side of
the cells.
• flexible fiberglass solar panels without glass components other than fiberglass, such panels
having power outputs ranging from 250 to 900 watts.
• solar panels consisting of solar cells arranged in rows that are laminated in the panel and that
are separated by more than 10 mm, with an optical film spanning the gaps between
all rows that is designed to direct sunlight onto the solar cells, and not including panels that lack
said optical film or only have a white or other backing layer that absorbs or scatters sunlight.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 5
CSPV cell.‐‐A crystalline silicon photovoltaic (“CSPV”) cell converts sunlight to electricity and is the basic
element of a module. The investigation covers CSPV cells of a thickness equal to or greater than 20
micrometers, having a p/n junction (or variant thereof) 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. Included are photovoltaic cells that contain
crystalline silicon in addition to other photovoltaic materials. This includes, but is not limited to,
passivated emitter rear contact (“PERC”) cells, heterojunction with intrinsic thin‐layer (“HIT”) cells, and
other so‐called “hybrid” cells.
CSPV 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.
CSPV products = CSPV cells + CSPV modules
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.
Bifacial.‐‐Bifacial modules that absorb light and generate electricity on each side of the module and that
consist of only bifacial cells that absorb light and generate electricity on each side of the cells.
Flexible fiberglass.‐‐Flexible fiberglass modules without glass components other than fiberglass, such
modules having power outputs ranging from 250 to 900 watts.
Light directing film.‐‐Modules consisting of cells arranged in rows that are laminated in the module and
that are separated by more than 10 mm, with an optical film spanning the gaps between all rows that is
designed to direct sunlight onto the cells, and not including modules that lack said optical film or only
have a white or other backing layer that absorbs or scatters sunlight.
Rear contact cells with tin‐coated solid copper fingers.‐‐Cells with a maximum rated power between 3.4
and 6.7 watts, inclusive, having the following characteristics: (A) A cell surface area between 154 cm2
and 260 cm2, inclusive, (B) no visible busbars or gridlines on the front of the cell, and (C) more than 100
interdigitated fingers of tin‐coated solid copper adhered to the back of the cell, with the copper portion
of the metal fingers having a thickness of greater than 0.01 mm.
Modules incorporating rear contact cells with tin‐coated solid copper fingers.‐‐Modules with a
maximum rated power between 320 and 500 watts, inclusive, having the following characteristics: (A)
Length between 1,556 mm and 2,070 mm inclusive, and width between 1,014 mm and 1,075 mm,
inclusive, (B) where the cells comprising the module have no visible busbars or gridlines on the front of
the cells, and (C) the cells comprising the module have more than 100 interdigitated fingers of tin‐
coated solid copper adhered to the back of the cells, with the copper portion of the metal fingers having
thickness greater than 0.01 mm.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 6
Low wattage.—Modules meeting one of the following eleven definitions:
(1) 10 to 60 watt, inclusive, rectangular modules, where the modules have the following characteristics:
(A) length of 250 mm or more but not over 482 mm or width of 400 mm or more but not over 635
mm, and (B) surface area of 1000 cm2 or more but not over 3,061 cm2), provided that no such
module with those characteristics shall contain an internal battery or external computer peripheral
ports at the time of entry; or
(2) 1 watt modules incorporated into nightlights that use rechargeable batteries and have the following
dimensions: 58 mm or more but not over 64 mm by 126 mm or more but not over 140 mm;
(3) 2 watt modules incorporated into daylight dimmers, that may use rechargeable batteries, such
modules with the following dimensions: 75 mm or more but not over 82 mm by 139 mm or more
but not over 143 mm;
(4) Off‐grid and portable CSPV modules, whether in a foldable case or in rigid form containing a glass
cover, where the modules have the following characteristics: (A) a total power output of 100 watts
or less per module; (B) a maximum surface area of 8,000 cm2 per module; (C) do not include a built‐
in inverter; (D) where the modules have glass covers, such modules must be in individual retail
packaging (for purposes of this provision, retail packaging typically includes graphics, the product
name, its description and/or features, and foam for transport);
(5) 3.19 watt or less modules, each with length of 75 mm or more but not over 266 mm and width of 46
mm or more but not over 127 mm, with surface area of 338 cm2 or less, 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 module edge, provided that no such module shall contain an internal battery or external
computer peripheral ports;
(6) 27.1 watt or less modules, each with surface area less than 3,000 cm2 and coated across the entire
surface with a polyurethane doming resin, the foregoing joined to a battery charging and
maintaining unit, such unit which is an acrylonitrile butadiene styrene (“ABS”) box that incorporates
a light emitting diode (“LED”) by coated wires that include a connector to permit the incorporation
of an extension cable.
(7) Off‐grid, 45 watt or less modules, each with length not exceeding 950 mm and width of 100 mm or
more but not over 255 mm, with a surface area of 2,500 cm2 or less, with a pressure‐laminated
tempered glass cover at the time of entry but not a frame, electrical cables or connectors, or an
internal battery; or
(8) 4 watt or less modules, each with a length or diameter of 70 mm or more but not over 235 mm, with
a surface area not exceeding 539 cm2, and not exceeding 16 volts, provided that no such module
with these characteristics shall contain an internal battery or external computer peripheral ports at
the time of entry; or
(9) Modules with a maximum rated power of equal to or less than 60 watts, having the following
characteristics, provided that no such module with those characteristics shall contain an internal
battery or external computer peripheral ports at the time of entry: (A) Length of not more than 482
mm and width of not more than 635 mm or (B) a total surface area not exceeding 3,061 cm2;
(10)Flexible and semi‐flexible off‐grid modules designed for use with motor vehicles and boats, where
the modules range in rated wattage from 10 to 120 watts, inclusive; or
(11)Frameless modules in a color other than black or blue with a total power output of 90 watts or less
where the modules have a uniform surface without visible cells or busbars.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 7
Reporting of information.‐‐If information is not readily available from your records in exactly the form
requested, furnish 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 to respond only once to duplicated questions in the questionnaires.
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 CFR §§ 206.17(a)(1) and 206.52(c)). 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 confidential business 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 Trade Act of 1974 (19 U.S.C. § 2252(i)) and sections 206.17 and 206.52
of the Commission’s Rules of Practice and Procedure (19 CFR §§ 206.17(a)(1) and 206.52(c)). 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.
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.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 8
Note.‐‐If your answers to questions in Part I differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain. Additional explanations may be included in II‐20.
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
Public reporting burden for this questionnaire is estimated to average 50 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 them to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐2a.
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment” – Each facility of a firm involved in the production of CSPV cells or the assembly
(full or partial) of CSPV cells into other products (e.g., laminates, panels, modules), including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
1
I‐2b.
I‐2c.
City, State
Zip (5 digit)
Description of activity
performed
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm: .
Lead attorney(s): .
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 9
Note.‐‐If your answers to questions in Part I differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain. Additional explanations may be included in II‐20.
I‐3.
Position regarding safeguard measure.‐‐Does your firm support or oppose the safeguard
measure applicable to imports of CSPV products?
Take no
Support
Oppose
position
Describe your position
I‐4.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Extent of
ownership
(percent)
Firm name
Address
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 10
Note.‐‐If your answers to questions in Part I differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain. Additional explanations may be included in II‐20.
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CSPV products into the United States or that are engaged
in exporting CSPV products to the United States?
No
Yes‐‐List the following information.
I‐6.
Firm name
Address
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of CSPV cells or the assembly (full or partial) of CSPV cells into other
products?
No
Yes‐‐List the following information.
I‐7.
Firm name
Address
Affiliation
Production/processing
activity performed
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 products?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 11
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.
Note.‐‐If your answers to questions in Part II differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain. Additional explanations may be included in II‐20.
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
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
II‐2.
Page 12
Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of CSPV cells or the assembly (full or partial) of CSPV cells
into other products since January 1, 2016.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions/mergers/buyouts
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Technology
Other
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 13
Note.‐‐If your answers to questions in Part II differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain. Additional explanations may be included in II‐20.
II‐3. Adjustment plans.‐‐Did your firm (or a prior owner of CSPV production assets) submit
adjustment plans to the Commission in connection with the original section 201 safeguard
investigation, Inv. No. TA‐201‐75 (Safeguard), or indicate to USTR since the initiation of the
original section 201 safeguard investigation that it would make adjustments in its operations
concerning CSPV products that would permit it to compete more effectively with imports of
CSPV products after relief expires if it were to receive import relief as a result of that
investigation?
Not known
II‐4.
No
Yes
If yes, please supply copies of the specific adjustment plans for your firm (or a
prior owner of CSPV production assets) as submitted to the Commission during
Inv. No. TA‐201‐75 (Safeguard) or to USTR since the initiation of the original
section 201 safeguard investigation. Also, please discuss below the reason(s)
why any specific adjustment actions included in the plans have NOT been
implemented (and are therefore not identified in your response to question II‐
2d). Please be specific as to the particular adjustment action that is being
discussed.
Significance of relief.‐‐Describe the significance of the safeguard measures imposed by the
President effective on February 7, 2018 (i.e., in the form of (a) a tariff‐rate quota on imports of
solar cells not partially or fully assembled into other products and (b) an increase in duties on
imports of CSPV modules), in terms of their effect on your firm’s operations in the following
categories. You may wish to compare your firm’s operations before and after the imposition of
the relief. Please explain how you have separated the effects of the safeguard measure from the
effects of other factors, such as closure or re‐opening of domestic production facilities, changes
in demand, exchange rate changes, or antidumping and countervailing duties.
Category
Production capacity, production, shipments,
inventories, and employment
Please describe the significance of the safeguard
measure.
Return on investment, ability to generate
capital to finance the modernization of
domestic plant(s) and equipment, or ability to
maintain existing levels of expenditures for
research and development
Changes in your firm’s collective bargaining
agreements (attach copies of all collective
bargaining agreements in effect or otherwise
agreed to by your firm since February 7, 2018)
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
II‐5.
Page 14
Efforts since implementation of safeguard measures.‐‐Since February 7, 2018, has your firm
undertaken any efforts to compete more effectively in the U.S. market for CSPV products?
No
Yes
II‐6.
If yes, please describe (1) any efforts made by your firm and/or its workers since
February 7, 2018 to compete more effectively, (2) the year in which the effort was
made, (3) the expenditure involved (in thousands of dollars), and (4) the specific
competitive advantage acquired (i.e., increased production, cost reduction, quality
improvement, increased market share or sales, etc.).
If you feel that any of these efforts have been made primarily to compete with
imported CSPV products, please indicate and explain. To the extent possible, furnish
the Commission with memoranda, studies, or other documentation which indicate
that such efforts were undertaken primarily to compete more effectively against
imports of CSPV products.
CSPV Cells.‐‐Since January 1, 2016, has your firm produced CSPV cells?
No
Yes‐‐Please complete questions II‐8 through II‐11 (CSPV cells in kilowatts).
Also, indicate below the type of cell for which data are being reported in this
questionnaire and provide an explanation concerning any product mix changes
that have occurred since January 1, 2016.
Check type of cell for which data are reported in this questionnaire. Check all that apply.
Mono cells
Multi cells
PERC cells
HIT cells
Bifacial cells
Other hybrid cells (please describe cell)
If checked, please provide explanation of any product mix changes since January 1, 2012.
II‐7.
CSPV Modules.‐‐Since January 1, 2016, has your firm produced CSPV laminates, panels, or
modules (regardless of the origin of the cell)?
No
Yes‐‐Please complete questions II‐12 through II‐15 (CSPV modules in kilowatts).
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 15
“Integrated producers of CSPV modules” (those U.S. firms that produce CSPV cells to be used in the
production of their CSPV modules) should report data regarding their CSPV cell production in questions II‐
10 through II‐12 (while reporting any cells used in downstream production of laminates, panels, modules,
etc. as "internal consumption") and report data regarding their CSPV module production in questions II‐
13 through II‐17.
“Assemblers of CSPV modules” (those U.S. firms that purchase or import CSPV cells from an unrelated
firm and assemble CSPV modules) should report data regarding their production in questions II‐13
through II‐17 (while indicating the various sources of their CSPV cells in the production data).
“Average production capacity” or “capacity” –The level of production that your establishment(s) could
reasonably have expected to attain during the specified periods. 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” or “Assembly” – All production or assembly in your U.S. establishment(s), including
production or assembly of items consumed internally within your firm and production or assembly of
items for another firm under a toll agreement.
“Commercial U.S. 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, including CSPV cells used to
assemble other CSPV products, such as modules, panels, and laminates.
“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, including
for example, parent companies, subsidiaries owned by the same parent company, and other affiliates.
Such transactions are valued at fair market value.
“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.
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. Producers’ Questionnaire –
CSPV Products (Monitoring)
II‐8.
Page 16
Production, shipment and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of CSPV cells in the U.S. establishment(s)
during the specified periods.
CELLS
Quantity (in kilowatts) and value (in $1,000)
Calendar year
Item
2016
2017
January‐June
2018
2018
2019
1
Average production capacity
(quantity) (A)
Beginning‐of‐period
inventories (quantity) (B)
Production:
Bifacial cells (quantity) (C)2
Rear contact cells with tin‐
coated solid copper fingers
(quantity) (D)2
All other cells (quantity) (E)
0
0
0
0
0
Unrelated firms:
quantity (N)
value (O)
Total cell production
U.S. shipments:
Commercial shipments:
quantity (F)
value (G)
3
Internal consumption:
quantity (H)
value (I)
3
Transfers to related firms:
quantity (J)
value (K)
Export shipments to‐‐
Related firms:5
quantity (L)
4
value (M)
6
End‐of‐period inventories
(quantity) (P)
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
II‐8.
Page 17
Production, shipment and inventory data: CSPV cells.—Continued
CELLS
Table footnotes continued from previous page.
1 The production capacity reported is based on operating
hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, explain any changes in reported capacity, and describe the constraint(s) that set
the limit(s) on your firm’s average production capacity (use additional pages as necessary). .
2 See definitions on pages 5‐7.
3 Internal consumption and transfers to related firms should be valued at fair market value. In the event that your firm uses a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data using that
basis for each of the periods noted above: .
4 If your firm’s cell exports are re‐imported into the United States in module form, please provide data in II‐9.
4 Identify your firm’s principal export markets to related firms: .
5 Identify your firm’s principal export markets to unrelated firms: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line P) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., lines C, D, and E), less total shipments (i.e., lines F, H, J, L, and N). 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
Item
B + C + D + E – F – H – J – L
– N – P = should equal zero
("0") or provide an
explanation.1
1
2016
2017
0
2018
0
2018
0
2019
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐9. U.S. shipments of re‐imported cells assembled into modules outside the United States.—If
your firm exported its U.S.‐produced cells (reported on lines L through O) and then re‐imported
those U.S.‐produced cells as assembled modules, report the quantity and value of your firm’s
total U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal U.S. consumption,
and transfers to U.S. related firms) of the imported modules assembled abroad from your firm’s
U.S.‐produced cells.
Quantity (in kilowatts) and value (in $1,000)
Calendar years
January‐June
Item
2016
2017
2018
2018
2019
U.S. shipments of CSPV modules
assembled outside the U.S. from
your firm’s U.S.‐produced cells:
Quantity (Q)
Value (R)
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 18
II‐10. Channels of distribution.‐‐Report the quantity and value of your firm’s total U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal U.S. consumption, and transfers to U.S. related
firms) of CSPV cells by channel of distribution.
CELLS
Quantity (in kilowatts) and value (in $1,000)
Calendar years
2016
2017
2018
January‐June
Item
2018
2019
Channels of distribution:
U.S. shipments of CSPV cells:
To module assemblers
Quantity (S)
Value (T)
To distributors
Quantity (U)
Value (V)
To residential installers
Quantity (W)
Value (X)
To commercial installers
Quantity (Y)
Value (Z)
To utilities/developers
Quantity (AA)
Value (AB)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities and values reported for channels of
distribution (i.e., lines S through AB) in each time period equal the quantities and values reported for
total U.S. shipments (i.e., lines F through K) 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
Item
2016
2017
2018
2018
2019
S + U + W + Y + AA – F –
H – J = zero ("0"), if not
revise.
0
0
0
0
0
T + V + X + Z + AB – G – I
– K = zero ("0"), if not
revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 19
II‐11. Employment data.‐‐Report your firm’s employment‐related data related to the production of
CSPV cells and provide an explanation for any trends in these data. If your firm assembles CSPV
modules from its own production of CSPV cells, the employment data reported here should
exclude employment data relating to your firm's assembly operations (so that PRW, hours
worked, and wages paid can be added to those reported in II‐16 to arrive at your firm's total
employment data).
CELLS
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and dividing that total by 12. For the January to June periods, calculate
similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” – Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
2016
2017
January‐June
2018
2018
2019
Average number of PRWs
(number) (AC)
Hours worked by PRWs
(1,000 hours) (AD)
Wages paid to PRWs
($1,000) (AE)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 20
II‐12. Production, shipment and inventory data: CSPV modules.‐‐Report your firm’s production
capacity, production, shipments, and inventories related to the production of CSPV modules in
its U.S. establishment(s) during the specified periods.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Calendar year
Item
2016
1
2017
January‐June
2018
2018
2019
Average production capacity (quantity) (AF)
Beginning‐of‐period inventories (quantity)
(AG)
Production of modules by source of cells‐‐
Internally consumed from own U.S.‐
produced cells (quantity) (AH)
Domestically purchased U.S.‐produced
cells2 (quantity) (AI)
Imported cells3 (quantity) (AJ)
0
0
0
0
0
Unrelated firms:
quantity (AS)
value (AT)
Total production of modules
U.S. shipments:
Commercial shipments:
quantity (AK)
value (AL)
4
Internal consumption:
quantity (AM)
value (AN)
4
Transfers to related firms:
quantity (AO)
value (AP)
Export shipments to‐‐
Related firms:5
quantity (AQ)
value (AR)
6
End‐of‐period inventories (quantity) (AU)
Table footnotes continued from next page.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 21
II‐12. Production, shipment and inventory data: CSPV modules.—Continued
MODULES
Table footnotes continued from previous page.
1 The production capacity reported is based on operating
hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, explain any changes in reported capacity, and describe the constraint(s) that set the
limit(s) on your firm’s average production capacity (use additional pages as necessary). .
2 Please specify the U.S. producers of the purchased U.S.‐origin cells your firm used for the production of these modules: .
Please also complete a U.S. Purchasers’ Questionnaire for these domestically purchased cells (available as a “fillable” form in MS Word
format on the Commission’s website at:
https://usitc.gov/investigations/title_7/2017/crystalline_silicon_photovoltaic_cells_whether_or/safeguard.htm)
3 Please specify country of origin of these cells: . If your firm was the importer of record for these imported cells, please also
complete a U.S. Importers’ Questionnaire. If your firm purchased these imported cells from an importer or distributor, please also
complete a U.S. Purchasers’ Questionnaire for these domestic purchases. These questionnaires are available as “fillable” forms in MS
Word format on the Commission’s website at:
https://usitc.gov/investigations/title_7/2017/crystalline_silicon_photovoltaic_cells_whether_or/safeguard.htm
4 See definitions on pages 15. Internal consumption and transfers to related firms should be valued at fair market value. In the event
that your firm uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above: .
5 Identify your firm’s principal export markets for relat/ed firms: .
6 Identify your firm’s principal export markets for unrelated firms: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line AU) should be equal to the beginning‐of‐period inventories (i.e., line
AG), plus production (i.e., lines AH, AI, and AJ), less total shipments (i.e., lines AK, AM, AO, AQ, and AS).
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
Item
AG + AH + AI + AJ ‐ AK ‐ AM ‐
AO ‐ AQ ‐ AS ‐ AU = should
equal zero ("0") or provide
an explanation.1
1
2016
2017
0
2018
0
2018
0
2019
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 22
II‐13. Channels of distribution.‐‐Report your firm’s total U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal U.S. consumption, and transfers to U.S. related firms) of CSPV modules
by channel of distribution.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Calendar years
Item
2016
Channels of distribution:
U.S. shipments of CSPV modules:
To module assemblers:
Quantity (AV)
2017
January‐June
2018
2018
2019
Value (AW)
To distributors:
Quantity (AX)
Value (AY)
To residential installers:
Quantity (AZ)
Value (BA)
To commercial installers:
Quantity (BB)
Value (BC)
To utilities/developers:
Quantity (BD)
Value (BE)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities and values reported for channels of
distribution (i.e., lines AV through BE) in each time period equal the quantities and values reported for
total U.S. shipments (i.e., lines AK through AP) 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
Item
2016
2017
2018
2018
2019
AV + AX + AZ + BB + BD –
AK – AM – AO = zero ("0"),
if not revise.
0
0
0
0
0
AW + AY + BA + BC + BE –
AL – AN – AP = zero ("0"),
if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 23
II‐14. Total U.S. shipments, by type.‐‐Report your firm’s total U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal U.S. consumption, and transfers to U.S. related firms) of
CSPV modules by type. See definitions of types on pages 5‐6.
MODULES
Quantity (in kilowatts), value (in $1,000)
Calendar year
Item
U.S. shipments of MODULES
incorporating:
Bifacial
Quantity (BF)
2016
2017
January‐June
2018
2018
2019
Value (BM)
Low wattage
Quantity (BN)
Value (BO)
0
0
0
0
0
Value (BG)
Flexible fiberglass
Quantity (BH)
Value (BI)
Light‐directing film
Quantity (BJ)
Value (BK)
Rear contact cells with tin‐coated
solid copper fingers
Quantity (BL)
All other CSPV modules
Quantity (BP)
Value (BQ)
Total, all module types
Quantity
Value
0
0
0
0
0
RECONCILIATION OF U.S. SHIPMENTS.—Total U.S. shipments of modules reported in II‐14 by type (lines
BF through BQ) should equal total U.S. shipments of modules reported in II‐12 (lines AK through AP).
Calendar years
January‐June
Reconciliation
2016
2017
2018
2018
2019
BF + BH + BJ + BL + BN + BP – AK ‐ AM –
AO = should equal zero ("0"), if not
revise
0
0
0
0
0
BG + BI + BK + BM + BO + BQ – AL – AN
– AP = should equal zero ("0"), if not
revise
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 24
II‐15. Employment data.‐‐Report your firm’s employment‐related data related to the production of
CSPV modules and provide an explanation for any trends in these data. If your firm produces its
own CSPV cells, the employment data reported here should relate solely to your firm's module
assembly operations (so that PRW, hours worked, and wages paid can be added to those
reported in II‐12 to arrive at your firm's total employment data).
MODULES
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated
with the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and dividing
that total by 12. For the January to June periods, calculate similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” – Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
2016
2017
January‐June
2018
2018
2019
Average number of PRWs
(number) (BR)
Hours worked by PRWs (1,000
hours) (BS)
Wages paid to PRWs ($1,000)
(BT)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 25
II‐16. Related firms.‐‐If your firm reported transfers to related firms in questions II‐8 or II‐12, please
indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non‐market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.
II‐17. Toll production.‐‐Since 2016, has your firm been involved in a toll agreement regarding the
production of CSPV cells or assembly (full or partial) of CSPV cells into other products (e.g.,
laminates, panels, modules)?
“Toll agreement” – Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 26
II‐18. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce CSPV cells or assemble (fully or
partially) CSPV cells into other products in and/or admit these items into a foreign trade
zone (FTZ)?
“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. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import CSPV products into a foreign trade zone (FTZ) for use in distribution of these
items and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 27
II‐19. Importer.‐‐Since January 1, 2016, has your firm imported CSPV products?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN THE U.S. IMPORTERS’ QUESTIONNAIRE
available as a “fillable” form in MS Word format on the Commission’s
website at:
https://usitc.gov/investigations/title_7/2017/crystalline_silicon_photovoltai
c_cells_whether_or/safeguard.htm
II‐20. Other explanations:‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 28
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Joana Lo (202‐205‐1888, joanna.lo@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
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for which
financial statements are prepared that include CSPV cells and/or CSPV modules:
2. Does your firm prepare profit/loss statements for CSPV cells and/or CSPV modules:
Yes
No
3. How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive basis of
accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes CSPV cells and/or CSPV
modules, as well as specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
III‐4.
Page 29
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced CSPV cells and/or CSPV modules, and provide the share of net sales accounted for by
these products in your firm’s most recent fiscal year.
Products
III‐6.
Share of sales in 2018
CSPV cells (do not include internal consumption)
%
CSPV modules
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CSPV cells and/or CSPV modules from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes‐‐Continue to question III‐7.
No‐‐Continue to question III‐9a.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
III‐7.
Page 30
Inputs from related suppliers.‐‐In the designated sections below and as applicable, please
identify the inputs your firm purchases from related suppliers that are reflected in table III‐9a
(Operations on CSPV cells (commercial sales and transfers)) and/or table III‐9c (Operations on
CSPV modules). For “Share of total COGS” please report this information by relevant input on
the basis of your most recently completed fiscal year. For “Input valuation” please describe the
basis, as recorded in the company’s own accounting system, of the purchase cost from the
related supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value, other.
Share of total COGS
Related supplier
in 2018
1
Operations on CSPV cells (commercial sales and transfers)
%
%
%
%
2
Operations on CSPV modules
%
%
%
%
1
Input valuation as recorded in the firm’s accounting books and records (Operations on CSPV cells
(commercial sales and transfers)):
2 Input valuation as recorded in the firm’s accounting books and records (Operations on CSPV
modules):
Input
III‐8.
Inputs from related suppliers at cost.‐‐Please confirm that the inputs purchased from related
suppliers, as identified in III‐7 above, were reported in III‐9a (Operations on CSPV cells
(commercial sales and transfers)) and/or III‐9c (Operations on CSPV modules) in a manner
consistent with the firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.:
For questions III‐9a and III‐9b, your firm should reported the data consistent with the like product
found in the original 201 safeguard, which includes products that were subsequently excluded
from the safeguard measures.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 31
III‐9a. Operations on CSPV cells (commercial sales and transfers).‐‐Report the revenue and related
cost information requested below on the CSPV cells operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that transfers to related firms must
be valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Companies whose fiscal years are not calendar years should report the fiscal years which most
closely correspond to calendar years 2016 through 2018. This table, while specific to CSPV cells
sold commercially or transferred, should be completed by integrated producers of CSPV
modules.
Note: The table below should reflect commercial sales and transfers and corresponding
costs/expenses associated with CSPV cells manufactured and sold by your firm as CSPV cells.
CSPV cells manufactured and/or purchased by your firm which were used internally to produce
CSPV modules, if any, should be reported as a component of raw material costs in table III‐9b
(Operations on CSPV modules).
CELLS (commercial sales and transfers only)
Quantity (in kilowatts) and value (in $1,000)
Fiscal years ended‐‐
Item
2016
2017
January‐June
2018
2018
2019
2
Net sales quantities:
Commercial sales
Transfers to related firms
0
0
0
0
0
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Transfers to related firms
Total net sales values
3
Cost of goods sold (COGS):
Polysilicon, Ingots
Wafers
All other raw material costs (CSPV
cells)
Direct labor (CSPV cells)
All other factory costs (CSPV cells)
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Continued on following page
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 32
III‐9a. Operations on CSPV cells (commercial sales and transfers).‐‐Continued
Quantity (in kilowatts) and value (in $1,000)
Fiscal years ended‐‐
Item
SG&A expenses:
Selling expenses
2016
2017
January‐June
2018
2018
2019
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
General and administrative expenses
Total SG&A expenses
Operating income or (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only CSPV cells commercial sales and/or transfers (whether domestic or export) and corresponding
costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the
corresponding CSPV cells shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CSPV cells commercial sales
and transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 33
III‐9b. Operations on CSPV modules.‐‐Report the revenue and related cost information requested
below on the CSPV modules operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption, to the extent applicable, and transfers to
related firms must be valued at fair market value. Input purchases from related suppliers should
be consistent with and based on information in the firm’s accounting books and records.
Provide data for your firm’s three most recently completed fiscal years, and for the specified
interim periods. Companies whose fiscal years are not calendar years should report the fiscal
years which most closely correspond to calendar years 2016 through 2018. This table should be
completed by integrated producers of CSPV modules and assemblers of CSPV modules.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Fiscal years ended‐‐
Item
2016
2017
January‐June
2018
2018
2019
2
Net sales quantities:
Commercial sales
Transfers to related firms
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
0
0
0
0
0
Direct labor (CSPV modules)
Other factory costs (CSPV modules)
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Other expenses and income:
Interest expense
All other expense items
All other income items
Total net sales quantities
2
Net sales values:
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Raw material costs4
SG&A expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Net income or (loss) before income taxes
Depreciation/amortization included above
Footnotes continued on next page.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 34
III‐9b. Operations on CSPV modules.‐‐Continued
1
Include CSPV modules commercial sales, internal consumption, and/or transfers (whether domestic or export) and
corresponding costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the
corresponding CSPV modules shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CSPV modules commercial sales,
internal consumption, and transfers.
4
Table III‐9c requests a breakout of the total raw material costs and will populate the raw material line item in this table.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS Word form fields.
III‐9c.
Components of total raw material costs of CSPV modules.‐‐Provide a breakout of the relevant
components of total raw material costs reported in question III‐9b (Operations on CSPV
modules). Provide data for your firm’s three most recently completed fiscal years, and for the
specified interim periods. Companies whose fiscal years are not calendar years should report
the fiscal years which most closely correspond to calendar years 2016 through 2018.
MODULES: Raw Materials
Value (in $1,000)
Fiscal years ended‐‐
Item
2016
Internally‐produced CSPV cells recognized in
III‐9b raw material costs:
Polysilicon, ingots
2017
January‐June
2018
2018
2019
Wafers
All other raw material costs (CSPV cells)
Direct labor (CSPV cells)
All other factory costs (CSPV cells)
0
0
0
0
0
Purchased CSPV cells recognized in III‐9b raw
material costs:
CSPV cells purchased from unrelated
domestically‐produced suppliers
CSPV cells purchased from foreign‐produced
suppliers
0
0
0
0
0
0
0
0
0
0
Total cost of internally‐produced CSPV
cells recognized in III‐9b raw material costs
Total cost of purchased CSPV cells
recognized in III‐9b raw material costs
Other raw material costs recognized in III‐9bc
raw material costs:
All other raw material costs
1
Total raw material costs (CSPV
modules)
1
The total raw material costs calculated in this table will populate the raw material cost line item in table III‐9b.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 35
III‐9d. Financial data reconciliation.‐‐The calculable line items from question III‐9a and III‐9b (i.e., total
net sales quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or
loss)) have been calculated from the data submitted in the other line items. Do these and other
calculated fields return the correct data according to your firm's financial records ignoring non‐
material differences that may arise due to rounding?
Yes
No‐‐If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise as necessary. If, after
reviewing and potentially revising the feeder data your firm has provided,
the differences between your records and the calculated fields persist,
please identify and discuss the differences in the space below.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
III‐10.
Page 36
Nonrecurring items (charges and gains) included in CSPV cells and CSPV modules financial
results.‐‐For each annual period for which financial results are reported in question III‐9a
(Operations on CSPV cells (commercial sales and transfers)) and III‐9b (Operations on CSPV
modules), please specify all material (significant) nonrecurring items (charges and gains) in the
schedule below, the specific question III‐9a and/or III‐9b line item where the nonrecurring items
are included, a brief description of the relevant nonrecurring items, and the associated values
(in $1,000), as reflected in table III‐9a and III‐9b; i.e., if an aggregate nonrecurring item has been
allocated to question III‐9a and/or III‐9b, only the allocated value amount included in question
III‐9a and/or III‐9b should be reported in the schedule below.
Note: The Commission’s objective here is to gather information only on material (significant)
nonrecurring items which impacted the financial results reported in question III‐9a and/or III‐9b.
Value ($1,000)
Fiscal years ended‐‐
Item
2016
2017
January‐June
2018
2018
2019
III‐9a‐‐Operations on CSPV cells (commercial sales and transfers):
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐9b‐‐Operations on CSPV modules:
Continued on following page.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 37
III‐10. Nonrecurring items (charges and gains).‐‐Continued
Nonrecurring item: In this table please provide a brief description of each nonrecurring item
reported above and indicate the specific line item in table III‐9a and/or III‐9b where the
nonrecurring item is classified.
Description of the nonrecurring item
Income statement classification
of the nonrecurring item
III‐9a‐‐Operations on CSPV cells (commercial sales and transfers):
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐9b‐‐Operations on CSPV modules:
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in table III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
III‐12.
Page 38
Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of CSPV cells and CSPV modules. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
CSPV cells and CSPV modules in the normal course of business, please estimate this information
based upon a method (such as production, sales, or costs) that is consistent with relevant cost
allocations in tables III‐9a and/or III‐9b. Provide data as of the end of your firm’s three most
recently completed fiscal years. Companies whose fiscal years are not calendar years should
report the fiscal years which most closely correspond to calendar years 2016 through 2018.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted. Total assets should be allocated to CSPV products if these assets are also related to
other non‐CSPV products. Assets used in the production of CSPV cells should be further
allocated to CSPV cells for commercial sales and/or transfer and CSPV cells for internal
consumption. In the notes to the table below, please provide a brief explanation if
there were any substantial changes in total asset value during the period; e.g., due to asset
write‐offs, revaluation, and/or major capital equipment purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2016
CSPV cell assets (net):
Used for commercial sales & transfers1
2017
2018
1
Total CSPV cell assets (net)
0
0
0
Used for internal consumption
2
3
Total CSPV modules (net)
1
Please allocate the total dollar amount of your firm’s CSPV cell assets separately for commercially
sold and/or transferred CSPV cells (reported in question III‐9a) and internally consumed CSPV cells
(reported in III‐9b).
2
Describe assets used for CSPV cells and explain substantial changes:
3
Describe assets used for CSPV modules and explain substantial changes:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 39
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses (“R&D”) for CSPV cells and CSPV
modules. Provide data for your firm’s three most recently completed fiscal years, and for the
specified interim periods. Companies whose fiscal years are not calendar years should report
the fiscal years which most closely correspond to calendar years 2016 through 2018.
Value (in $1,000)
Fiscal years ended‐‐
Item
2016
CSPV cells:
Capital expenditures1
2
R&D expenses
CSPV modules:
Capital expenditures3
4
R&D expenses
2017
January‐June
2018
2018
2019
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on CSPV cells.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to CSPV cells.
3
Please describe the nature, focus, and significance of your firm’s capital expenditures on CSPV modules.
4
Please describe the nature, focus, and significance of your firm’s R&D expenses related to CSPV modules.
2
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9b, III‐12, and III‐13 are based on a calendar year or your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Note: The quantities and values reported in question III‐9a and/or III‐9b should reconcile with
the data reported in question II‐5 and/or II‐9 (including export shipments) as long as they are
reported on the same calendar year basis.
Continued on following page.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 40
III‐14. Data consistency and reconciliation.—Continued
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis. If the calculated fields below return values other than zero (i.e., “0”) and both are being reported
on a calendar basis, please explain the discrepancy below.
CSPV cells (commercial sales and transfers only)
Full year data
Reconciliation
2016
2017
January‐June
2018
2019
2018
Quantity: Corresponding trade data
from part II (table II‐10) less financial
data from table III‐9a, = zero ("0")
except as noted above.
0
0
0
0
0
Value: Corresponding trade data from
part II (table II‐10) less financial data
from table III‐9a, = zero ("0") except as
noted above.
0
0
0
0
0
Do these data in III‐9a reconcile with data in II‐8?
Yes
No
If no, please explain.
CSPV modules (commercial sales, internal consumption, and transfers)
Full year data
Reconciliation
2016
2017
January‐June
2018
2019
2018
Quantity: Trade data from part II
(table II‐13) less financial data from
table III‐9b, = zero ("0") except as
noted above.
0
0
0
0
0
Value: Trade data from part II (table
II‐13) less financial data from table III‐
9b, = zero ("0") except as noted
above.
0
0
0
0
0
Do these data in question III‐9b reconcile with data in question II‐12?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 41
III‐15. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 42
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Aimee Larsen (202‐205‐
3179, Aimee.Larsen@usitc.gov).
IV‐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 IV.
Name
Title
Email
Telephone
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following modules that your firm that
your firm manufactured domestically using either U.S.‐produced CSPV cells or imported CSPV
cells.
Product 1.‐‐ Multicrystalline silicon module with front‐side area of less than 1.9 square meters
and a peak power wattage between 240w to 290w, inclusive, P‐max or Wp as
measured under Standard Test Conditions (“STC”).
Product 2.‐‐ Monocrystalline silicon module with front‐side of less than 1.9 square meters and
a peak power wattage between 270w to 320w, inclusive, P‐max or Wp as
measured under Standard Test Conditions (“STC”).
Product 3.‐‐ Multicrystalline silicon module with front‐side area of greater than or equal to 1.9
square meters and a peak power wattage between 290w to 340w, inclusive,
P‐max or Wp as measured under Standard Test Conditions (“STC”).
Product 4.‐‐ Monocrystalline silicon module with front‐side area of less than 1.9 square
meters and a peak power wattage between 325w to 375w, inclusive, P‐max or
Wp as measured under Standard Test Conditions (“STC”).
Product 5.‐‐ Monocrystalline silicon module with front‐side area of greater than or equal to
1.9 square meters and a peak power wattage between 325w to 375w, inclusive,
P‐max or Wp as measured under Standard Test Conditions (“STC”).
Product 6.‐‐ Monocrystalline silicon module with front‐side area of greater than or equal to
1.9 square meters and a peak power wattage between 380w to 430w, inclusive,
P‐max or Wp as measured under Standard Test Conditions (“STC”).
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 43
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).
During January 2016‐June 2019, did your firm produce 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 IV‐4.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 44
IV‐2a. Price data.—Report below the quarterly price data1 for pricing products2 produced (i.e.,
assembled) in the United States and sold by your firm using U.S.‐produced CSPV cells.
Modules manufactured from cells produced in the United States
Report data in kilowatts and actual dollars (not 1,000s).
Product 1
(Quantity in kilowatts, value in dollars)
Product 2
Value
Quantity
Value
Product 3
Period of
shipment
Quantity
Quantity
Value
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2019:
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 IV.
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:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 45
IV‐2a. Price data.—Continued.
Modules manufactured from cells produced in the United States
Report data in kilowatts and actual dollars (not 1,000s).
Product 4
(Quantity in kilowatts, value in dollars)
Product 5
Value
Quantity
Value
Product 6
Period of
shipment
Quantity
Quantity
Value
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2019:
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 IV.
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 4:
Product 5:
Product 6:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 46
IV‐2b. Price data.—Report below the quarterly price data1 for pricing products2 (i.e., assembled) in the
United States and sold by your firm using imported CSPV cells.
Modules manufactured in the United States from imported cells
Report data in kilowatts and actual dollars (not 1,000s).
Product 1
(Quantity in kilowatts, value in dollars)
Product 2
Value
Quantity
Value
Product 3
Period of
shipment
Quantity
Quantity
Value
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2019:
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 IV.
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:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 47
IV‐2b. Price data.—Continued.
Modules manufactured in the United States from imported cells
Report data in kilowatts and actual dollars (not 1,000s).
Product 4
(Quantity in kilowatts, value in dollars)
Product 5
Value
Quantity
Value
Product 6
Period of
shipment
Quantity
Quantity
Value
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2019:
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 IV.
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 4:
Product 5:
Product 6:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
IV‐3.
Page 48
Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data that you reported above in response to questions
IV‐2a, and IV‐2b.
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.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 49
Note.‐‐If your answers to questions in Part IV differ for CSPV cells or CSPV modules (or some other such
breakout), then please explain.
IV‐4. Price setting.—Has your firm changed how it determines the prices that it charges for sales of
CSPV products (transaction‐by‐transaction, contracts, set price lists, etc.) since February 7, 2018.
IV‐5.
IV‐6.
IV‐7.
No
Yes
If yes, please describe.
Discount policy.‐‐ Has your firm changed its discount policies since February 7, 2018?
No
Yes
If yes, please describe.
Contract versus spot.‐‐Since February 7, 2018, has the approximate share of your firm’s sales of
its U.S.‐produced CSPV products sold on a short‐term contract basis, annual contract basis, long‐
term contract basis, and spot sales basis changed?
No
Yes
If yes, please describe.
Lead times.‐‐Has the average lead time between a customer’s order and the date of delivery for
your firm’s sales of its U.S.‐produced CSPV products changed since February 7, 2018?
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
IV‐8.
IV‐9.
Page 50
Geographical shipments.—Has there been any change in the U.S. geographic market area(s) in
which your firm sold its U.S.‐produced CSPV products since February 7, 2018?
No
Yes
If yes, please describe.
Availability of supply.—
(a) Has the availability of CSPV cells in the U.S. market changed since February 7, 2018?
Availability of cells in the
Please explain, noting the countries and reasons for the
U.S. market
No Yes changes.
Changes since February 7, 2018:
U.S.‐produced product
Imports from other
countries
(b) Has the availability of CSPV modules in the U.S. market changed since February 7, 2018?
Availability of modules
Please explain, noting the countries and reasons for the
in the U.S. market
No Yes changes.
Changes since February 7, 2018:
U.S.‐produced product
Imports from other
countries
IV‐10. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply CSPV products
since February 7, 2018 (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. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 51
IV‐11. Effect of section 232 duties on raw material prices.‐‐Did the announcement of the 232
investigation in April 2017 or the subsequent imposition of tariffs on imported steel and
aluminum products beginning in March 2018 have an impact on the raw material prices for
CSPV products?
Yes—Please indicate the impact in
the table below.
No
Don’t know
Item
Fluctuate
with no
clear
No
trend
Increase change Decrease
Explanation and factors
Raw material costs for
CSPV products in the
U.S. market
Prices for CSPV
products in the U.S.
market
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 52
IV‐12. Impact of section 301 duties.— This question concerns the section 301 investigation and
subsequent announcement of additional tariffs that include CSPV products proposed and
implemented by the United States in response to Chinese trade practices.
(a) Did the announcement of the 301 investigation in June 2018 or the subsequent imposition of
tariffs on Chinese‐origin products have an impact on the CSPV products market?
Yes— Please indicate the impact in
the table below.
No
Don’t know
(b) Please indicate the impact of the announcements and subsequent imposition of duties under
the section 301 investigation.
Item
No
Fluctuate
Overall
Overall
with no
increase change decrease clear trend Explanation and factors
Overall demand/anticipated
demand for CSPV products in
the U.S. market
Supply/anticipated supply of
CSPV products in the U.S.
market
Prices/anticipated prices for
CSPV products in the U.S.
market
Raw material costs/anticipated
raw material costs for CSPV
products in the U.S. market
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 53
IV‐13. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for CSPV products has changed since February 7, 2018, 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
Sector
Overall
increase
Fluctuate
with no
clear
No
Overall
change decrease trend
Explanation and factors
Demand since February 7, 2018
Residential
Within the
Commercial
United States
Utility
Outside the
United States
All sectors
Anticipated future demand
Residential
Within the
Commercial
United States
Utility
Outside the
United States
All sectors
IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
technology, or marketing of CSPV products since February 7, 2018?
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 54
IV‐15. Conditions of competition.‐‐Have there been any changes in the business cycles or conditions
of competition for CSPV products since February 7, 2018?
IV‐16.
No
Yes
Overall
increase
No
change
Overall
decrease
Fluctuate
with no
clear trend
Incentives and explanation of
demand trends
State and local
government incentives
Federal government
incentives
Conventional energy sources.—How have changes in the price of electricity generated from
U.S. conventional energy sources affected the price of solar generated electricity since
February 7, 2018? Explain any trends and describe the principal factors that have affected
these changes in price.
Overall
No
price
Change in
increase
price
Government incentives.—Have changes in the level or availability of government incentives
affected demand for CSPV products since February 7, 2018? In the last column, list or describe
the principal incentive programs (e.g., Solar Investment Tax Credit , Section 1603 Program,
Renewable Portfolio Standards, or California Solar Initiative) whose change in level or
availability has affected demand.
Market
IV‐17.
If yes, describe.
Overall
price
decrease
Fluctuate
with no
clear trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 55
IV‐18. Price related factors.—
(a) Please indicate whether changes in the following factors have tended to increase, decrease,
or have no effect on the prices of CSPV products in the U.S. market since February 7, 2018.
Factor
Increased
Decreased
No effect
Competition between U.S. producers
Level of competition from substitute products
(e.g. thin film)
Level of competition from imports
Cost of raw materials
Domestic production capacity
Allocation of production capacity to alternate
products
Productivity of domestic producers
Labor agreements, contracts, etc.
Transportation/delivery cost
Market patterns
Demand in the United States
Demand outside the United States
State and local government incentives
Prices of conventional energy
Technology improvements
Section 201 Safeguard measures
Other:
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 56
IV‐18. Price related factors.—Continued.
(b) Please rate the importance of changes in the following factors based on their contribution to
the prices of CSPV products since February 7, 2018.
Factor
Very
important
Somewhat
important
Not
important
Competition between U.S. producers
Level of competition from substitute products
(e.g. thin film)
Level of competition from imports
Cost of raw materials
Domestic production capacity
Allocation of production capacity to alternate
products
Productivity of domestic producers
Labor agreements, contracts, etc.
Transportation/delivery cost
Market patterns
Demand in the United States
Demand outside the United States
State and local government incentives
Prices of conventional energy
Technology improvements
Section 201 Safeguard measures
Other:
(c) Please provide any detailed discussion/elaboration on factors affecting price changes of
CSPV products in the U.S. market since February 7, 2018.
Business Proprietary
U.S. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 57
IV‐19. Efforts since implementation of safeguard measures.—Has your firm made any efforts to
increase product availability to your customers, either in terms of the quantity of products
available or by increasing your product offerings (e.g., new size ranges, qualities, features,
products, etc.) since February 7, 2018?
No
Yes
If yes, describe.
IV‐20. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV 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. Producers’ Questionnaire –
CSPV Products (Monitoring)
Page 58
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/title_7/2019/crystalline_silicon_photovoltaic_cell
s_whether_or/safeguard.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: CSPV
• E‐mail.‐‐E‐mail the MS Word questionnaire to Mary Messer (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 their 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 produce CSPV products, 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 C.F.R. § 206.17). 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 C.F.R. § 206.17). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producers--Solar panels (201)(Monitoring) |
| Author | mary.messer |
| File Modified | 2019-08-20 |
| File Created | 2019-08-20 |