20-3-4167 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4167; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
VERTICAL SHAFT ENGINES FROM CHINA
This survey must be received by the Commission by January 29, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping duty investigations concerning vertical shaft engines from
China (Inv. Nos. 701-TA-637 and 731-TA-1471 (Preliminary)). The information requested in the questionnaire is
requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed
can result in a subpoena or other order to compel the submission of records or information in your firm’s possession (19
U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased, or imported for its own use, vertical shaft engines (as defined on next page) at any
time since January 1, 2016?

NO

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

YES

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

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

Title of Authorized Official

Date

Signature

Phone

Email address

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on January 15, 2020, by the
Coalition of American Vertical Engine Producers (Kohler Co., Kohler, Wisconsin, and Briggs & Stratton
Corporation, Wauwatosa, Wisconsin). Countervailing and/or antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes affirmative determinations of
injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an
affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/vertical_shaft_engines_china/preliminary.htm.
Vertical shaft engines covered by these investigations are spark-ignited, non-road, vertical shaft
engines, whether finished or unfinished, whether assembled or unassembled, designed primarily for use
in riding lawn mowers and zero-turn radius lawn mowers. Engines meeting this physical description may
also be designed for use in other non-hand-held outdoor power equipment. The subject engines are
spark ignition, single or multiple cylinder, air cooled, internal combustion engines with vertical power
take off shafts with a minimum displacement of 225 cubic centimeters ("cc") and a maximum
displacement of 999cc. Typically, engines with displacements of this size generate gross power of
between 6. 7 kilowatts ("kw'') to 42 kw.
Engines covered by this scope normally must comply with and be certified under Environmental
Protection Agency (EPA) air pollution controls title 40, chapter I, subchapter U, part 1054 of the Code of
Federal Regulations standards for small non-road spark-ignition engines and equipment. Engines that
otherwise meet the physical description of the scope but are not certified under 40 CFR part 1054 and
are not certified under other parts of subchapter U of the EPA air pollution controls are not excluded
from the scope of this proceeding. Engines that may be certified under both 40 CFR part 1054 as well as
other parts of subchapter U remain subject to the scope of this proceeding.
For purposes of these investigations, an unfinished engine covers at a minimum a sub-assembly
comprised of, but not limited to, the following components: crankcase, crankshaft, camshaft, pistons(s),
connecting rod(s), and oil pan. Importation of these components together, whether assembled or
unassembled, and whether or not accompanied by additional components such as a manifold, cylinder
head(s), valve train, or valve cover(s), constitutes an unfinished engine for purposes of these
investigations. The inclusion of other products such as spark plugs fitted into the cylinder head or
electrical devices (e.g., ignition modules, ignition coils) for synchronizing with the motor to supply
tension current does not remove the product from the scope. The inclusion of any other components
not identified as comprising the unfinished engine subassembly in a third-country does not remove the
engine from the scope.
The engines subject to these investigations are typically classified in the Harmonized Tariff Schedule of
the United States (HTSUS) at statistical reporting numbers: 8407.90.1020, 8407.90.1060, and
8407.90.1080. Engines subject to these investigations may also enter under HTSUS 8407.90.9060 and
8407.90.9080. The engine subassemblies that are subject to these investigations enter under HTSUS
8409.91.5085, and 8409.91.9990. The HTSUS statistical reporting numbers are provided for convenience
and customs purposes only, and the written description of the merchandise under investigation is
dispositive.

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.--The data furnished in response to this survey that reveal the individual operations of
your firm will be treated as confidential by the Commission to the extent that such data are not
otherwise available to the public and will not be disclosed except as may be required by law (see 19
U.S.C. 1677f). Such confidential information will not be published in a manner that will reveal the
individual operations of your firm; however, general characterizations of numerical business proprietary
information (such as discussion of trends) will be treated as confidential business information only at the
request of the submitter for good cause shown.
Release of information.--The information provided by your firm in response to this survey, as well as
any other business proprietary information submitted by your firm to the Commission in connection
with this proceeding, may become subject to, and released under, the administrative protective order
provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the Commission’s Rules of
Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and other authorized
individuals may temporarily be given access to the information for use in connection with this
proceeding or other import-injury proceedings conducted by the Commission on the same or similar
merchandise; those individuals would be subject to severe penalties if the information were divulged to
unauthorized individuals. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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PURCHASE INFORMATION
1. Purchases and imports.— Report separately your firm’s domestic purchases and imports of vertical
shaft engines.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.

2016

2017

Item

JanuarySeptember
2019

2018

Quantity (in units)

Purchases of vertical shaft engines
produced in—
United States
China
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

0

0

Imports of vertical shaft engines
from—
China
All other countries1
Total imports3
1

Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported vertical shaft engines at any time since January 1, 2016, please also complete and
return a U.S. importers' questionnaire in this proceeding.
2

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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2. Changes in purchasing patterns.—Please indicate how the shares of your firm’s purchases of
vertical shaft engines from different sources have changed since January 1, 2016.
Source of
purchases

Did not
purchase

Decreased Increased

Constant

Fluctuated

Explanation for trend

United States

China

All other
countries
Sources
unknown

3. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase vertical shaft engines.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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4. Purchasing subject imports rather than domestic products.—
(a)

Since January 2016, did your firm import and/or purchase imports of vertical shaft
engines from China instead of purchasing U.S.-produced vertical shaft engines?
Source

Yes
(also respond to parts (b) and (c))

No
(If “No”, skip to next question)

China
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

China
(c)

If you responded “Yes” to part (a), was price a primary reason for importing and/or
purchasing subject imports rather than domestic product?

Source

China

Yes

If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2016
(in units)

No

If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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5. U.S. producers and import competition.—
(a)

Since January 1, 2016, in connection with a sale or offer to sell vertical shaft engines to
your firm, did U.S. producers reduce their prices of domestically produced vertical shaft
engines in order to compete with lower-priced imports of vertical shaft engines from
China?
Source

Yes (also respond to
question part (b))

No (If “No”, skip to next
question)

Don’t know

China
(b)

If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices, and any additional explanations, such as
timing (e.g., months/years), frequency of price reductions, or other market/competitive
factors.

Source
China

Estimated
reduction in U.S.
prices
(percent)

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

%

6. Other explanations--Please provide any additional comments in this box.

7. Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the stock
exchange and trading symbol:
.
8. 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):

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Lost Sales and Lost Revenue Survey- Vertical Shaft Engines (Preliminary)

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

Dollars

The questions in this survey have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited
as possible. Public reporting burden for this survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey or cannot use one of the electronic methods
of submission, please contact the Commission for further instructions.
• Upload via Secure Drop Box.—Upload the MS Word survey along with a scanned copy of the signed
certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: ENGCN

• E-mail.—E-mail the MS Word survey to cindy.cohen@usitc.gov; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop-box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non-encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.