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U.S. IMPORTERS’ QUESTIONNAIRE
DIFLUROMETHANE (R‐32) FROM CHINA
This questionnaire must be received by the Commission by February 6, 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 antidumping investigation concerning difluoromethane (“R‐32”) from China (Inv. No. 731‐TA‐1472
(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 imported R‐32 (as defined on next page) from any country at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: DIFLU)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐ This proceeding was instituted in response to a petition filed on January 23, 2020, by
Arkema Inc., King of Prussia, Pennsylvania. Antidumping duties may be assessed on the subject imports
as a result of these proceedings if the Commission makes an affirmative determination of injury, threat,
or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of dumping. Questionnaires and other information pertinent to this proceeding are
available at
http://wwwadmin.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/preliminary.htm
_0.
Difluoromethane (“R‐32”) covered by this investigation is difluoromethane (“R‐32”) or its chemical
equivalent, regardless of form, type or purity level. R‐32 has the Chemical Abstracts Service (“CAS”)
registry number of 75‐10‐5 and the chemical formula CH2F2. R‐32 is also referred to as difluoromethane,
HFC‐32, FC‐32, Freon‐32, methylene difluoride, methylene fluoride, carbon fluoride hydride, halocarbon
R32, fluorocarbon R32, and UN 3252.
Subject merchandise also includes R‐32 and unpurified R‐32 that are processed in a third country or the
United States, including, but not limited to, purifying or any other processing that would not otherwise
remove the merchandise from the scope of this investigation if performed in the country of
manufacture of the in‐scope R‐32. R‐32 that has been blended with products other than
pentafluoroethane (R‐125) is included within this scope if such blends contain 85% or more by volume
on an actual percentage basis of R‐32. In addition, R‐32 that has been blended with any amount of R‐125
is included within this scope if such blends contain more than 52% by volume on an actual percentage
basis ofR‐32. Whether R‐32 is blended with R‐125 or other products, only the R‐32 component of the
mixture is covered by the scope of these orders. The scope also includes R‐32 that is commingled with R‐
32 from sources not subject to this investigation. Only the subject component of such commingled
products is covered by the scope of this order.
Excluded is merchandise covered by the scope of the antidumping order on Hydrofluorocarbon Blends
from the People's Republic of China. See Hydrofluorocarbon Blends from the People's Republic of China,
81 Fed. Reg. 55436 (Aug. 19, 2016).
R‐32 is currently imported under statistical reporting numbers 2903.39.2035 of the Harmonized Tariff
Schedule of the United States (HTSUS). It may also be imported under HTSUS statistical reporting
numbers 2903.39.2045 and 3824.78.0020. The HTSUS provisions are for convenience and customs
purposes; the written description of the scope is dispositive.
Importer.‐‐Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing R‐32 (as defined above) into the United States from a foreign manufacturer or through its
selling agent.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 3
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.‐‐If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Ahdia
Bavari (202‐205‐3191, ahdia.bavari@usitc.gov).
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. Importers’ Questionnaire ‐ R‐32 (Preliminary)
I‐1.
Page 4
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
I‐2a.
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”‐‐Each facility of a firm involved in the importation of R‐32, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
I‐2b.
I‐2c.
Page 5
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).
I‐3.
I‐4.
Law firm:
Lead attorney(s):
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Firm name
Country
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing R‐32 from China into the United States or that are
engaged in exporting R‐32 from China to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
I‐5.
I‐6.
Page 6
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of R‐32?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Importing operations.‐‐Please indicate the nature of your firm’s importing operations on R‐32.
More than one answer may be applicable.
Importer of record
I‐7.
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Consignee.‐‐If your firm is an importer of record of R‐32 but is not the consignee, please list the
consignees below (firm name, address, telephone number, and individual to contact).
Firm name
Address
Contact person
and phone
number
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
I‐8.
Page 7
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters R‐32 into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports R‐32 under the TIB (temporary importation under bond) program.
“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, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re‐export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item
I‐9.
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Other trade actions.‐‐To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
I‐10.
No
Yes
If yes, please specify.
Restrictions on imports of R‐32.‐‐To your knowledge, are there any restrictions on imports of R‐
32 in the United States as a result of actions aimed at reducing chemicals such as R‐32 that may
harm the environment? This may include EPA restrictions and/or the Montreal Protocol and
subsequent amendments.
No
Yes–Please specify.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained Ahdia Bavari (202‐205‐3191,
ahdia.bavari@usitc.gov). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the importation of R‐32 since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 9
II‐3a. Arranged imports.‐‐Has your firm imported or arranged for the importation of R‐32 for delivery
after December 31, 2019?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No
Yes
If yes, fill out the table below.
Period
Source
Jan‐Mar 2020
II‐4.
Apr‐Jun 2020
Jul‐Sept 2020
Oct‐Dec 2020
Quantity (in short tons)
China
All other sources
Reasons for importing if producer.‐‐If your firm also produces R‐32 in the United States, please
indicate the reasons for importing this product. If your firm’s reasons differ by source, please
elaborate.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 10
Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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. This excludes
commercial arms‐length transactions that involve, at least in part, non‐monetary “in kind”
transactions (a.k.a., swap transactions). 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. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Swaps” –Shipments made commercially in arms‐length transactions that involve, at least in
part, non‐monetary “in kind” transfer of product.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“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. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 11
II‐5a. U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of R‐32 imported from China by your firm during the specified periods.
China
Quantity (in short tons), value (in $1,000)
Calendar years
Item
2017
Beginning‐of‐period inventories
(quantity) (A)
2018
2019
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
2
Value (G)
Transfers to related firms:
Quantity (H)
Value2 (I)
2
3
Swaps :
Quantity (J)
4
Value (K)
Export shipments:5
Quantity (L)
Value (M)
End‐of‐period inventories
(quantity) (N)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Please (1) identify the companies from which your firm receives the goods or services in‐kind, (2) indicate the particular
goods or services in‐kind received pursuant to your swap transactions, and (3) quantify any net monetary exchange included
in the swap transactions in each calendar year: .
4
Report the value inclusive of the “in kind” value of any goods or services received plus the net monetary transferred in
the swap transactions.
5
Identify your firm’s principal export markets: .
2
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 12
II‐5a. U.S. imports from China.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line N) should be equal to the beginning‐of‐period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar years
Reconciliation
2017
A + B – D – F – H – J – L – N = should
equal zero ("0") or provide an
explanation.1
2018
2019
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐5b. Channels of distribution: China.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) by channel of distribution.
China
Calendar years
Item
2017
2018
2019
Quantity (in short tons)
Channels of distribution:
U.S. shipments:
To distributors and service
companies (O)
To HFC component
blenders (P)
To OEMs and other non‐
blender end users (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H,
and J) 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 years
Reconciliation item
O + P + Q – D – F – H – J = zero ("0"),
if not revise.
2017
2018
0
2019
0
0
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 13
II‐6a. Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of R‐32 imported from all other sources by your firm during the specified periods.
All other sources
(list sources:
)
Quantity (in short tons), value (in $1,000)
Calendar years
Item
2017
Beginning‐of‐period inventories
(quantity) (A)
2018
2019
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
Value2 (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
Swaps3:
Quantity (J)
4
Value (K)
2
5
Export shipments:
Quantity (L)
Value (M)
End‐of‐period inventories
(quantity) (N)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Please (1) identify the companies from which your firm receives the goods or services in‐kind, (2) indicate the particular
goods or services in‐kind received pursuant to your swap transactions, and (3) quantify any net monetary exchange included
in the swap transactions in each calendar year: .
4
Report the value inclusive of the “in kind” value of any goods or services received plus the net monetary transferred in
the swap transactions.
5
Identify your firm’s principal export markets: .
2
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 14
II‐6a. Imports from all other sources.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line N) should be equal to the beginning‐of‐period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar years
Reconciliation
2017
A + B – D – F – H – J – L – N = should
equal zero ("0") or provide an
explanation.1
2018
2019
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐6b. Channels of distribution: All other sources.‐‐Report your firm’s U.S. shipments by channel of
distribution.
All other sources
Calendar years
Item
2017
2018
2019
Quantity (in short tons)
Channels of distribution:
U.S. shipments:
To distributors and service
companies (O)
To HFC component
blenders (P)
To OEMs and other non‐
blender end users (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H,
and J) 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 years
Reconciliation item
2017
2018
O + P + Q – D – F – H – J = zero ("0"),
if not revise.
0
2019
0
0
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
II‐7.
Page 15
Transfers to related firms.‐‐If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non‐market formula.
II‐8.
Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 16
PART III.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202‐205‐2049,
Natalia.King@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
PRICE DATA
III‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products your firm imported
from China:
Product 1.‐‐ R32, sold in bulk to blenders
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 2017 ‐December 2019, did your firm import from China 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 as appropriate.
No.‐‐Skip to question III‐3.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 17
III‐2a. Price data.‐‐Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.
China
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Quantity
Period of shipment
Value
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
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 III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with
the specified product, provide a description of your firm’s product. Also, please explain any anomalies
in your firm’s reported pricing data.
Product 1:
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 18
III‐2b. Price data checklist.‐‐Please check that the pricing data in question III‐2(a) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
In pounds (not short tons)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in part II in each year?
III‐2c. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
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.
PURCHASE COST DATA
III‐3.
This question requests quarterly quantity and landed‐duty paid value data for your firm’s
imports of the products defined above (on the first page of part III) for internal consumption
from China since January 1, 2017. These are imports that your firm does not resell as R‐32.
During January 2017‐December 2019, did your firm import any of the products listed on the first
page of part III from China for internal consumption?
Yes.‐‐Please complete the following table as appropriate.
No.‐‐Skip to question III‐4.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 19
III‐3a. Imports for internal use.—Report below the import data1 for pricing products2 imported from
China and used by your own firm. These are imports that your firm does not resell as R‐32.
China
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Period of importation
Quantity
LDP Value
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
1 LDP value (i.e., landed duty‐paid values): Values reported should be landed, duty‐paid values at
the U.S. port of entry, including ocean freight and insurance costs, brokerage charges, and import duties
(i.e., all charges except inland freight in the United States). See “Import values” definition in Part II
(Trade and Related Information – Definitions).
2 Pricing product definitions are provided on the first page of Part III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with
the specified product, provide a description of your firm’s product. Also, please explain any anomalies
in your firm’s reported pricing data.
Product 1:
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 20
The following questions ask about the costs/benefits (not included in the LDP values reported above)
that factor into your firm’s decision to import R‐32 rather than purchase from a U.S. producer or
importer of R‐32.
III‐3b. Additional costs for your firm’s imports of R‐32 for your firm’s internal use.—
i.
Did your firm incur any additional costs by importing R‐32 rather than purchasing from a
U.S. producer or importer (e.g., logistical or supply chain management costs,
warehousing/inventory carrying costs, insurance or other risk management fees,
demurrage fees, indirect and overseas costs)?
No
ii.
iii.
Yes—Please answer parts ii, iii, and iv.
Please provide an estimate of the total additional cost incurred (as a percentage
compared to LDP value) when importing R‐32 rather than purchasing from a U.S.
producer or importer. (Report only the portion that is related to your firm’s importing
activities, either directly or indirectly, and not already included in the LDP value. Do NOT
include any costs that also would be incurred if your firm purchased the product from a
U.S. producer or importer.) percent compared to LDP value.
Please identify and explain the specific additional costs incurred by your firm and
estimate each cost (in percent) compared to the cost of importing. (Only report costs
and the portion of each cost that was related to your firm’s importing activities for R‐32,
either directly or indirectly, and that are not already included in the LDP value. Do NOT
report costs that your firm would incur when purchasing R‐32 from a U.S. producer or
importer.)
Costs
iv.
Explanation
Briefly describe how your firm’s additional costs (beyond the purchase price) by
importing R‐32 directly compare with the additional costs your firm incurs when
purchasing from a U.S. producer or U.S. importer.
Estimated
percentage
compared to LDP
value (percent)
%
%
%
%
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 21
III‐3c. Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import R‐32? Check all that apply.
U.S. importers
U.S. producers
Neither U.S. importers
nor U.S. producers
III‐3d. Benefits of importing R‐32.
i.
Briefly identify the benefits of importing R‐32 instead of purchasing R‐32 from a U.S.
importer or from a U.S. producer.
ii.
Is it your firm’s experience that the R‐32 your firm imported from China are priced lower
than they would be if your firm purchased from a U.S. importer or U.S. producer?
Imports are priced lower when
iii.
No
Yes (If yes to either, please
answer parts iii and iv.)
Not including the additional costs above
Including the additional costs above
Please estimate your firm’s savings by importing R‐32 instead of purchasing from a U.S.
producer or U.S. importer since January 1, 2017 (as a percent of the purchase price from
the U.S. importer or U.S. producer). For your estimate, compare the price of purchasing
from a U.S. importer or U.S. producer to the cost of direct imports (including the
additional costs described above in III‐3b).
Factors
iv.
Estimated savings
(percent of purchase price from
U.S. importer/producer)
U.S. producer
%
U.S. importer
%
What methods or experience did you base the estimates in III‐3diii (i.e. based on
previous transactions with U.S. producers and/or U.S. importers, market research, etc.)
Check all that apply.
Reported estimates in III‐3diii based on
√ if Yes
Previous company transactions
Market research
Other – Please explain
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 22
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of these data, as Commission staff may contact your firm regarding questions. 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.
If your firm imports R‐32 for internal use only, please skip to question III‐12.
III‐4. Price setting.‐‐How does your firm determine the prices that it charges for sales of R‐32 (check
all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
III‐5.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
III‐6.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of imported R‐32 from China usually quoted
(check one)?
Delivered
F.o.b.
III‐7.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of R‐32 imported from
China in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term
contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
III‐8.
Page 23
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for R‐
32 imported from China (or check “not applicable” if your firm does not sell on a short‐term,
annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period) 1
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs2
Not applicable
365
1
Please explain how contract terms are renegotiated (i.e., meet or release clause):
Please identify the indexes used:
2
III‐9.
Lead times.‐‐What is your firm’s share of sales of R‐32 imported from China from inventory and
produced to order and what is the typical lead time between a customer’s order and the date of
delivery for your firm’s sales of R‐32?
Lead time
(Average number
of days)
Source
Share of 2019 sales
From your firm’s U.S. inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 24
III‐10. Shipping information.—
(a)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
(b)
When your firm sells R‐32 imported from China, from where is it shipped?
Point of importation Storage facility (check one)
(c)
Indicate the approximate percentage of your firm’s sales of R‐32 imported from China
that are delivered the following distances from your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
III‐11. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold R‐32
imported from subject countries since January 1, 2017 (check all that apply)?
Geographic area
China
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
III‐12. Inland transportation costs.—What is the approximate percentage of the cost of R‐32 imported
from China that is accounted for by U.S. inland transportation costs? percent.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 25
III‐13. End uses.‐‐List the end uses of the R‐32 that your firm imports. For each end‐use product, what
percentage of the total cost is accounted for by R‐32 and other inputs?
Share of total cost of end‐use product
accounted for by
Total
(should sum to
100.0% across)
R‐32
Other inputs
End‐use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
III‐14. Substitutes.‐‐Can other products be substituted for R‐32?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for R‐32?
No Yes
Explanation
1.
2.
3.
III‐15. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for R‐32 has changed since January 1, 2017. Explain any trends and describe
the principal factors that have affected these changes in demand.
Overall
No
Overall Fluctuate with
increase change decrease no clear trend
Market
Explanation and factors
Within the United States
Outside the United States
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 26
III‐16. Product changes.‐‐Have there been any significant changes in the product range, product mix or
marketing of R‐32 since January 1, 2017?
No
Yes
If yes, please describe.
III‐17. Conditions of competition.—
(a) Is the R‐32 market subject to business cycles (other than general economy‐wide conditions)
and/or other conditions of competition distinctive to R‐32?
Check all that apply.
Please describe.
No
Skip to question III‐18.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
R‐32 since January 1, 2017?
No
Yes
If yes, describe.
III‐18. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply R‐32 since
January 1, 2017 (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. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 27
III‐19. Raw materials.‐‐How have R‐32 raw material prices changed since January 1, 2017?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for R‐32.
III‐20. Interchangeability.‐‐Is R‐32 produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing R‐32 that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that
limit or preclude interchangeable use:
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 28
III‐20. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between R‐32 produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or
frequently are a significant factor in your firm’s sales of R‐32, identify
the country‐pair and report the advantages or disadvantages imparted
by such factors:
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 29
III‐21. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for R‐32 since January 1, 2017. Indicate the share of the quantity of your firm’s total
shipments of R‐32 that each of these customers accounted for in 2019.
Customer’s name
Contact person
Email
Telephone
City
State
Share of
2019
sales (%)
1
2
3
4
5
6
7
8
9
10
III‐22. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 30
Correcting Valid number error messages.‐‐If you are completing a Commission
questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The U.S. International Trade Commission’s
questionnaires are set‐up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.
Business Proprietary
U.S. Importers’ Questionnaire ‐ R‐32 (Preliminary)
Page 31
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
http://wwwadmin.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/
preliminary.htm_0.
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: DIFLU
• E‐mail.—E‐mail the MS Word questionnaire to ahdia.bavari@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 import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - U.S. Importers questionnaire--R-32(P) |
| Author | ahdia.bavari |
| File Modified | 2020-01-24 |
| File Created | 2020-01-24 |