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pdfOMB No. 3117-0016/USITC No. 18-1-3832; Expiration Date: : 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
RUBBER BANDS FROM CHINA, SRI LANKA, AND THAILAND
This questionnaire must be received by the Commission by February 13, 2018
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 and countervailing duty investigations concerning rubber bands from China, Sri Lanka,
and Thailand (Inv. Nos. 701-TA-598-600 and 731-TA-1408-1410 (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 produced rubber bands (as defined on next page) and/or select excluded rubber band products
(as defined on next page) from any country at any time since January 1, 2015?
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: BAND)
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
Phone:
Signature
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on January 30, 2018 by
Alliance Rubber Co., Hot Springs, Arkansas. Antidumping and countervailing 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 and subsidization. Questionnaires and
other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/rubber_bands_china_sri_lanka_and_thailand/preli
minary.htm.
Rubber bands covered by these investigations are defined as bands made of vulcanized rubber, with a
flat length, as measured end-to-end by the band lying flat, no less than 1/2 inch and no greater than 10
inches; with a width, which measures the dimension perpendicular to the length, of at least 3/64 inch
and no greater than 2 inches; and a wall thickness from 0.020 inch to 0.125 inch. Vulcanized rubber has
been chemically processed into a more durable material by the addition of sulfur or other equivalent
curatives or accelerators. Subject products are included regardless of color or inclusion of printed
material. The scope includes vulcanized rubber bands which are contained or otherwise exist in various
fowls and packages, such as, without limitation, vulcanized rubber bands included within a desk
accessory set or other type of set or package, and vulcanized rubber band balls, but excludes Bedford
Elastitags®, and bands that are being used at the time of import to fasten an imported product.
Rubber bands are currently imported under statistical reporting number 4016.99.3510 of the
Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions are for convenience and
customs purposes; the written description of the scope is dispositive.
Select excluded (or out-of-scope) rubber band products are as follows: (1) Vulcanized rubber bands with
a flat length less than 1/2 inches or greater than 10 inches, a width less than 3/64 inches or greater than
2 inches, or a wall thickness less than 0.020 inches or greater than 0.125 inches (“Excluded vulcanized
rubber bands”); (2) Bedford Elastitags®; and (3) Non-latex rubber bands.
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.
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.
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 3
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of rubber bands and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
I-1a.
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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 to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
I-2.
Page 4
Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. 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 rubber bands, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
I-3.
Additional discussion on establishments consolidated in this questionnaire:
.
Petition support.--Does your firm support or oppose the petition?
Petition
Support
Oppose
Take no position
China AD
China CVD
Sri Lanka AD
Sri Lanka CVD
Thailand AD
Thailand CVD
I-4.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
Yes--List the following information.
Address
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
I-5.
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing rubber bands from China, Sri Lanka, and/or Thailand into
the United States or that are engaged in exporting rubber bands from China, Sri Lanka, and/or
Thailand to the United States?
No
Firm name
I-6.
Page 5
Yes--List the following information.
Country
Affiliation
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of rubber bands?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 6
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, amanda.lawrence@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax
II-2.
Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of rubber bands since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(If checked, please describe; leave blank if not applicable)
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-3a.
Page 7
Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce rubber bands, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Overall 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).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in pounds)
Calendar years
Item
2015
2016
2017
Overall production capacity
Production of:
In-scope rubber bands1
0
0
0
0
0
0
0
0
0
Products not covered:
Excluded vulcanized rubber bands2
Bedford Elastitags®
Non-latex rubber bands
Other products3
Subtotal, products not covered
Total
1
Data entered for production of in-scope rubber bands will populate here once reported in question II-7.
Excluded vulcanized rubber bands, as defined on page 2, include bands made of vulcanized rubber with a flat
length less than 1/2" or greater than 10”, a width less than 3/64” or greater than 2”, and a wall thickness less
than 0.020” or greater than 0.125”.
3
Please identify these products:
.
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on operating
per week,
weeks per year.
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
hours
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 8
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II-3e.
Product shifting.—
(i)
Is your firm able to switch production (capacity) between in-scope rubber bands and other
products using the same equipment and/or labor?
No
(ii)
II-4.
Yes-- (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of in-scope rubber bands?
“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 – Rubber Bands (Preliminary)
II-5.
Page 9
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce in-scope rubber bands in and/or admit
in-scope rubber bands 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
(b)
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import in-scope rubber bands into a foreign trade zone (FTZ) for use in distribution of inscope rubber bands and/or the production of downstream articles?
No
II-6.
Yes
If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
Yes
If yes--Identify the firms and the FTZs.
Importer.--Since January 1, 2015, has your firm imported in-scope rubber bands and/or select
excluded rubber band 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 A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-7.
Page 10
Production, shipment, and inventory data of in-scope rubber bands.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of inscope rubber bands in its U.S. establishment(s) during the specified periods.
“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” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Bulk 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. For the purposes of this
questionnaire, bulk commercial U.S. shipments should include sales to distributors, to end users,
and to retail establishments, whether or not already packaged for retail sale, but should not
include sales made at the retail level of trade to individual customers (including to other
businesses).
“Internal consumption / including for retail sale” --Product consumed internally by your firm
and product that is destined for sale at a retail level to individual consumers. Such transactions
should be valued at fair market value of the bulk in-scope rubber bands (i.e., not the retail
price).
“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.
“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 – Rubber Bands (Preliminary)
II-7.
Page 11
Production, shipment, and inventory data of in-scope rubber bands.--Continued
Quantity (in pounds) and value (in dollars)
Calendar years
2015
Item
2016
2017
1
Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Bulk commercial shipments:
Quantity (D)
Value (E)
Internal consumption (including for retail sale by
2
your firm):
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
Value (I)
Export shipments:
Quantity (J)
3
Value (K)
4
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
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
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero ("0")
or provide an explanation.1
1
2015
2016
0
2017
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
0
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-8.
Page 12
Channels of distribution.--Report your firm’s U.S. shipments (i.e., inclusive of bulk commercial
U.S. shipments, internal consumption, and transfers to related firms) of in-scope rubber bands
by channel of distribution.
Quantity (in pounds)
Calendar years
Item
2015
2016
2017
Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers and office supply stores: branded1 (N)
To retailers and office supply stores: private label1 (O)
To end users: agricultural/floral/grocery (P)
To end users: industrial/hardware/construction (Q)
To end users: newspaper/packaging/stationery2 (R)
To end users: all other end users3 (S)
1
Include stationery stores, such as Staples, Office Depot, etc., in retail category.
Include end users, such as government or post offices, that purchase rubber bands for stationery use in end
users category.
3
Please specify the other types of end users:
.
2
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through S) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) 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
M + N + O + P + Q + R + S – D – F – H = zero ("0"), if not revise.
2015
2016
0
2017
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-9.
Page 13
U.S. shipments by product size.--Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of in-scope rubber bands
produced by your firm by product size.
Quantity (in pounds)
Item
Calendar year
2017
U.S. shipments.-Rubber bands balls (T)
Other than rubber band balls:
Sizes 8 through 19 and 117-A1 (U)
Sizes 27 through 33 and 117-B2 (V)
All other sizes (W)3
1
Sizes 8 through 19 and 117-A, based on common industry standards, have a width of 1/16”. Lengths are
as follows: size 8—7/8”, size 10—1 ¼”, size 12—1 ¾”, size 14—2”, size 16—2 ½”, size 18—3”, size 19—3 ½”,
and size 117-A—7”.
2
Sizes 27 through 33 and 117-B, based on common industry standards, have a width of 1/8”. Lengths are
as follows: size 27—1 ¼”, size 30—2”, size 31—2 ½”, size 32—3”, size 33—3 ½”, and size 117-B—7”.
3
Please specify the other sizes:
.
RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
US shipments by product type (i.e., lines T through W) in 2017 equal the quantity and value
reported for U.S. shipments (i.e., lines D through I) in 2017 in question II-7. 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.
Reconciliation
Quantity: T + U + V + W – D – F – H = zero ("0"), if not
revise.
Calendar year
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-10.
Page 14
Employment data.--Report your firm’s employment-related data related to the production of inscope rubber bands and provide an explanation for any trends in these data.
“Production and 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 divide
that total by 12.
“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 years
Item
2015
2016
2017
Average number of PRWs (number)
Hours worked by PRWs (number of hours)
Wages paid to PRWs (dollars)
Explanation of trends:
II-11.
Related firms.--If your firm reported transfers to related firms in question II-7, 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 nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
II-12.
Page 15
Purchases.--Other than direct imports, has your firm otherwise purchased in-scope rubber
bands since January 1, 2015?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
No
Yes--Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in pounds)
Calendar years
Item
2015
2016
2017
1
Purchases from U.S. importers of inscope rubber bands from—
China
Sri Lanka
Thailand
All other countries
Purchases from domestic producers2
Purchases from other sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
II-13.
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 – Rubber Bands (Preliminary)
Page 16
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Janet Freas (202-205-3107,
janet.freas@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
Fax
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 rubber bands:
2.
Does your firm prepare profit/loss statements for rubber bands:
Yes
No
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,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)
3.
4.
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 rubber bands, 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 – Rubber Bands (Preliminary)
Page 17
III-4.
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 in-scope rubber bands, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products
In-scope rubber bands
Share of sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
III-6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of rubber bands 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.
III-7.
Page 18
No--Continue to question III-9a.
Inputs from related suppliers.--Please identify the inputs used in the production of rubber
bands that your firm purchases from related suppliers and that are reflected in question III-9a.
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 your 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.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
III-8.
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on rubber bands)
in a manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 19
III-9a. Operations on in-scope rubber bands.--Report the revenue and related cost information
requested below on the in-scope rubber bands operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption 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.
Quantity (in pounds) and value (in dollars)
Fiscal years ended-Item
2015
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials
3
Direct labor
Other factory costs
Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2
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 – Rubber Bands (Preliminary)
Page 20
III-9b. Raw materials for rubber bands.--Please indicate the share of total raw material costs reported
in III-9a in 2017 for the following raw material inputs:
Input costs
Natural rubber
Synthetic rubber
Other input costs (e.g., pigments, dyes)1
Total (should sum to 100 percent)
Share of 2017 total
raw material costs
(percent)
%
%
%
0.0 %
1
Please indicate any notable "other" raw materials not expressly identified above and
provide the share of the 2017 total raw material costs that they account for:
III-9c.
Financial data reconciliation.--The calculable line items from question III-9a (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 the 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.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
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 – Rubber Bands (Preliminary)
Page 21
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual period for which financial results are reported in question III-9a, please specify all
material (significant) nonrecurring items (charges and gains) in the schedule below, the specific
question III-9a line item where the nonrecurring items are included, a brief description of the
relevant nonrecurring items, and the associated values (in dollars), as reflected in question III9a; i.e., if an aggregate nonrecurring item has been allocated to question III-9a, only the
allocated value amount included in question III-9a 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 reported financial results of the subject product in
question III-9a.
Fiscal years ended--
2015
Nonrecurring item: In this column please provide a brief
description of each nonrecurring item and indicate the
specific line item in table III-9a where the nonrecurring item
is classified.
1.
, classified as
2.
, classified as
3.
, classified as
4.
, classified as
5.
, classified as
6.
, classified as
7.
, classified as
2016
2017
Nonrecurring item: In these columns please report the amount
of the relevant nonrecurring item reported in question III-9a.
Value (in dollars)
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 question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 22
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of rubber bands. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for rubber bands 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 question III-9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years ended-Item
Total assets (net)
1
III-13.
2015
2016
2017
1
Describe
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for rubber bands. Provide data for your
firm’s three most recently completed fiscal years.
Value (in dollars)
Fiscal years ended--
Item
Capital expenditures
2015
2016
2017
1
Research and development expenses
2
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 23
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
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.
Full year data
Reconciliation
2015
2016
2017
Quantity: Trade data from question II-7
(lines D, F, H, and J) less financial total net
sales quantity data from question III-9a, =
zero ("0").
0
0
0
Value: Trade data from question II-7 (lines E,
G, I, and K) less financial total net sales value
data from question III-9a, = zero ("0").
0
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 24
If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2015, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of rubber bands from China, Sri Lanka, and Thailand?
No
Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 25
III-16. Effects of imports on growth and development.--Since January 1, 2015, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of rubber bands from China, Sri Lanka, and
Thailand?
No
Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
(please describe)
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 26
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
rubber bands from China, Sri Lanka, and Thailand?
No
Yes
If yes, my firm anticipates negative effects as follows:
III-18. 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 – Rubber Bands (Preliminary)
Page 27
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202-2053489, lauren.gamache@usitc.gov).
IV-1.
Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax
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, 2015 of the following products produced by your
firm.
Product 1.-- Size #32 rubber bands (3” x 1/8”), natural/latex, sold in 1 lb. poly bags
Product 2.-- Size #33 rubber bands (3 1/2” x 1/8”), natural/latex, sold in 1 lb. poly bags
Product 3.-- Size #64 rubber bands (3 1/2” x 1/4”), natural/latex, sold in 1 lb. poly bags
Product 4.-- Size #18 rubber bands (3” x 1/16”), newspaper size, natural/latex, sold in 1 lb. poly
bags
Product 5.-- Size #14 rubber bands (2" x 1/16"), agricultural size, natural/latex, sold in 1 lb. poly
bags
Product 6.-- Size #16, rubber bands (2 ½" x 1/16”), agricultural size, natural /latex, sold in 1 lb.
poly bags
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).
IV-2 (a). During January 2015-December 2017, 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-3.
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 28
IV-2(b). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and dollars.
Period of shipment
(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Quantity
Value
(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value
Product 6
Quantity
Value
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
Period of shipment
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
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 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 your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 4:
Product 2:
Product 5:
Product 3:
Product 6:
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 29
IV-2 (c). Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000) and pounds?
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?
IV-2 (d). 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.
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of rubber bands
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Set
price
lists
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
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
IV-5.
Pricing terms.-(a)
What are your firm’s typical sales terms for its U.S.-produced rubber bands?
Net 30
days
(b)
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of its domestic rubber bands usually quoted (check
one)?
Delivered
IV-6.
Page 30
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced rubber
bands in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?
Long-term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2017
sales
%
Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
IV-7.
Page 31
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced rubber bands (or check “not applicable” if your firm does not sell on a long-term,
short-term and/or annual contract basis).
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries for
more than 12 months)
365
No
Quantity
Fixed quantity
and/or price
Price
Both
Yes
Meet or release
provision
No
Not applicable
IV-8.
Lead times.--What is your firm’s share of sales 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 its U.S.-produced rubber bands?
Source
Share of 2017 sales
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Lead time
(Average number
of days)
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
IV-9.
Page 32
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced rubber bands that is
accounted for by U.S. inland transportation costs?
percent
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(c)
Indicate the approximate percentage of your firm’s sales of rubber bands that are
delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0
%
IV-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced rubber bands since January 1, 2015 (check all that apply)?
Geographic area
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.
√ if applicable
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 33
IV-11. End uses.--List the end uses of the rubber bands that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by rubber bands and other inputs?
Share of total cost of end use product
accounted for by
End use product
Rubber bands
Total
(should sum
across to
100.0%)
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-12. Substitutes.--Can other products be substituted for rubber bands?
No
Substitute
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for rubber bands?
No Yes
Explanation
1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for rubber bands has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Within the United States
Outside the United States
Overall
increase
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 34
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of rubber bands since January 1, 2015?
No
Yes
If yes, please describe and quantify if possible.
IV-15. Conditions of competition.-(a) Is the rubber band market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to rubber bands? If yes,
describe.
Check all that apply.
Please describe.
No
Skip to question IV-16.
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
rubber bands since January 1, 2015?
No
Yes
If yes, describe.
IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply rubber bands
since January 1, 2015 (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.
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 35
IV-17. Raw materials.--How have rubber bands raw material prices changed since January 1, 2015?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no
have affected your firm’s selling prices for rubber
increase change decrease clear trend
bands.
IV-18. Bundling sales.--Does your firm bundle sales of rubber bands with other products?
No
Yes
Estimate share
of your rubber
band sales
that were sold
in a bundle in
2017
Describe other product(s) that are typically in bundled
sales
IV-19. Interchangeability.--Are rubber bands 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
China
Sri Lanka
Thailand
Other countries
United States
China
Sri Lanka
Thailand
For any country-pair producing rubber bands that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 36
IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between rubber bands 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
China
Sri Lanka
Thailand
Other countries
United States
China
Sri Lanka
Thailand
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of rubber bands, identify the country-pair and report the advantages
or disadvantages imparted by such factors:
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 37
IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for rubber bands since January 1, 2015. Indicate the share of the quantity of your
firm’s total shipments of rubber bands that each of these customers accounted for in 2017.
Customer’s name
1
2
3
4
5
6
7
8
9
10
Contact person
Email
Telephone
City
State
Share of
2017
sales (%)
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U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
Page 38
IV-22. Competition from imports
(a)
Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling rubber
bands from China, Sri Lanka, and Thailand, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2015: Did your firm lose sales of rubber bands to imports of
this product from China, Sri Lanka, and Thailand?
No
(c)
Yes
The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: BAND)
IV-23. 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 – Rubber Bands (Preliminary)
Page 39
PART V.-- ALTERNATIVE PRODUCTS
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, amanda.lawrence@usitc.gov).
V-1.
Comparability of rubber band products.--For each of the following product pairs indicate
whether in-scope rubber bands produced in the United States are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
Note.--Excluded vulcanized rubber bands, as defined on page 2, include bands made of vulcanized
rubber with a flat length less than 1/2" or greater than 10”, a width less than 3/64” or greater than 2”,
and a wall thickness less than 0.020” or greater than 0.125”.
(a) Physical Characteristics and Uses.--The differences and similarities in the physical
characteristics and uses.
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their physical characteristics and uses:
(b) Interchangeability.--The ability to substitute the products in the same application.
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their interchangeability:
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
V-1.
Page 40
Comparability of rubber band products.--Continued
(c) Common manufacturing facilities, production processes, and production
employees.--Whether manufactured in the same facilities, from the same inputs, on
the same machinery and equipment, and using the same employees.
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their common manufacturing facilities, production
processes, and production employees:
(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesalers/distributors, etc.).
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their channels of distributon:
(e) Consumer and producer perceptions.--Perceptions as to the differences and/or
similarities.
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their consumer and producer perceptions:
Business Proprietary
U.S. Producers’ Questionnaire – Rubber Bands (Preliminary)
V-1.
Page 41
Comparability of rubber band products.--Continued
(f) Price.--Whether prices are comparable or differ between products.
Product-pair
Excluded vulcanized
rubber bands
Bedford Elastitags®
Non-latex rubber bands
In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their price:
V-2.
U.S. shipments of out-of-scope rubber bands.--Report your firm’s U.S. shipments of out-ofscope rubber band products (i.e. excluded vulcanized rubber bands, as defined on page 2,
Bedford Elastitags®, and non-latex rubber bands). Data reported in question V-2 should not be
included in data reported in part II.
Quantity (in pounds)
Calendar years
Item
2015
2016
2017
U.S. shipments:
Excluded vulcanized rubber bands:
Quantity
Value
Bedford Elastitags®:
Quantity
Value
Non-latex rubber bands:
Quantity
Value
V-3.
Other explanations.--If your firm would like to further explain a response to a question in Part V
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 – Rubber Bands (Preliminary)
Page 42
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2018/rubber_bands_china_sri_lanka_and
_thailand/preliminary.htm.
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: BAND
• E-mail.—E-mail the MS Word questionnaire to amanda.lawrence@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 does not produce 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 (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | US producer questionnaire |
| Subject | Title 7 investigations |
| Author | Lawrence, Amanda |
| File Modified | 2018-01-31 |
| File Created | 2018-01-31 |