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pdfOMB No. 3117-0016/USITC No. 18-1-3908; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
STEEL RACKS FROM CHINA
This questionnaire must be received by the Commission by July 5, 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 countervailing duty and antidumping investigations concerning steel racks from China (Inv. Nos. 701TA-608 and 731-TA-1420 (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 steel racks (as defined on next page) 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: SRACK)
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 - Steel racks (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 20, 2018, by Bulldog
Rack Company, Weirton, West Virginia; Hannibal Industries, Inc., Los Angeles, California; Husky Rack and
Wire, Denver, North Carolina; Ridg-U-Rak, Inc., North East, Pennsylvania; SpaceRAK, A Division of
Heartland Steel Products, Inc., Marysville, Michigan; Speedrack Products Group, Ltd., Sparta, Michigan;
Steel King Industries, Inc., Stevens Point, Wisconsin; Tri-Boro Shelving & Partition Corp., Farmville,
Virginia; and UNARCO Material Handling, Inc., Springfield, Tennessee. Countervailing and/or
antidumping duties may be assessed on the subject imports as a result of these proceedings if the
Commission makes an affirmative determination of injury, threat, or material retardation, and if the U.S.
Department of Commerce (“Commerce”) makes an affirmative determination of subsidization and/or
dumping. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_racks_china/preliminary.htm.
Steel racks covered by these investigations is steel racks and parts thereof, assembled or unassembled.
Steel racks are racks made of steel of dimensions and configurations that can be adjusted as required,
with or without locking tabs or slots, and with or without bolted, clamped, or welded connections,
including any of the following: uprights, posts, columns, braces, frames, beams, arms, locking devices,
and rails.
A steel rack is a structure typically made from cold-formed or hot-rolled steel structural members and
includes, but is not limited to, components such as plates, rods, angles, shapes, sections, tubes and the
like. Welding, bolting, and clipping are the typical methods of assembly. Connections may also be made
with locking devices such as clips, end plates, and beam connectors. Steel racks may be made to ANSI
MH16.1 or ANSI MH16.3. All steel racks and parts thereof meeting the physical description set out
herein are covered by the scope of this investigation, whether or not produced according to a particular
standard.
The vertical components of steel racks may be referred to as posts, columns, or uprights, and may be
connected with horizontal or diagonal braces to form upright frames. A typical storage configuration
comprises upright frames perpendicular to the aisles, independently adjustable, positive locking beams
parallel to the aisle and spanning between the upright frames, and braces designed to support unit loads
between the beams. A cantilever rack consists of uprights running parallel to the aisle and cantilever
beams or arms connected to the uprights and running perpendicular to the aisle rather than spanning
two upright frames.
The scope includes all steel racks and parts thereof meeting the description above, regardless of: (1)
dimensions, weight, strength, gauge, or load rating; (2) vertical upright or frame type (including
structural, roll-form, or other); (3) horizontal support or beam / brace type (including but not limited to
structural, roll-form, slotted, unslotted, Z-beam, C-beam, L-beam, step beam, cantilever beam, and
cargo rack); (4) number of supports; (5) number of levels; (6) surface coating, if any (including but not
limited to paint, epoxy, powder coating, zinc, and other metallic coating); (7) shape (including but not
limited to rectangular, square, corner, and cantilever); (8) the method by which the vertical and
horizontal supports connect (including but not limited to locking tabs or slots, bolting, clamping, and
welding); and (9) the inclusion or not of moving components (including but not limited to rails, wheels,
rollers, tracks, channels, carts, and conveyors).
Steel racks may be referred to as pallet racks, storage racks, stacker racks, retail racks, pick modules, or
cantilever racks. Steel racks that incorporate moving components may also be referred to as pallet flow
racks, carton flow racks, push back racks, movable shelf racks, drive-in racks, and drive-through racks.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 3
Subject merchandise includes material matching the above description that has been finished,
assembled, or packaged in a third country, including by coating, painting, assembling, attaching to, or
packaging with another product, or any other finishing, assembly, or packaging that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the steel racks and parts thereof.
Steel racks and parts thereof are covered whether or not imported attached to, or in conjunction with,
other parts and accessories such as wire decking, nuts, and bolts. If steel racks and parts thereof are
imported attached to, or in conjunction with, such non-subject merchandise, only the steel racks and
parts thereof are covered by the scope.
Specifically excluded from the scope of this investigation are any products covered by the existing
antidumping and countervailing duty orders on boltless steel shelving units prepackaged for sale from
the People’s Republic of China. See Boltless Steel Shelving Units Prepackaged for Sale From the People’s
Republic of China: Antidumping Duty Order, 80 Fed. Reg. 63,741 (October 21, 2017); Boltless Steel
Shelving Units Prepackaged for Sale From the People’s Republic of China: Amended Final Affirmative
Countervailing Duty Determination and Countervailing Duty Order, 80 Fed. Reg. 63,745 (October 21,
2017).
Merchandise covered by this investigation is currently classified in the Harmonized Tariff Schedule of the
United States (HTSUS) under the following subheadings: 7326.90.86881 and 9403.20.0080.2 Subject
merchandise may also enter under subheadings 7308.90.3000, 7308.90.6000, 7308.90.9590, and
9403.20.0090. The HTSUS subheadings set forth above are provided for convenience and U.S. Customs
purposes only. The written description of the scope is dispositive.
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.
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
Prior to January 1, 2017, such merchandise was classified under HTS statistical reporting number 7326.90.8588.
From July 1, 2015 through December 31, 2017, such merchandise was classified under HTS statistical reporting
number 9403.20.0080. Prior to July 1, 2015 such merchandise was classified under HTS statistical reporting
number 9403.20.0020.
1
2
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 4
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 steel racks 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.
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 macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
I-1a.
Page 5
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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
I-2.
No
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 steel racks, 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
Additional discussion on establishments consolidated in this questionnaire:
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
I-3.
Petitioner status.--Is your firm the petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Page 6
Yes
Petition support.--Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China AD
China CVD
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-6.
Yes--List the following information.
Address
Extent of
ownership
(percent)
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing steel racks from China into the United States or that are
engaged in exporting steel racks from China to the United States?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
I-7.
Page 7
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of steel racks?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amelia Shister (202-2052047, Amelia.Shister@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 production of steel racks 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 - Steel racks (Preliminary)
Page 9
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce steel racks, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
II-3a.
“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).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope mercandhise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“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
Overall production capacity
2016
January-March
2017
2017
2018
1
Production of:
Steel racks2
0
0
0
0
0
0
0
0
0
0
Out-of-scope production
3
Total production using same
machinery or workers
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of steel racks will populate here once reported in question II-7.
3
Please identify these products:
.
1
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week
Weeks per year
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 10
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.
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 steel racks and other products
using the same equipment and/or labor?
No
(ii)
II-4.
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of steel racks?
“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 - Steel racks (Preliminary)
II-5.
Page 11
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce steel racks in and/or admit steel racks
into a foreign trade zone (FTZ)?
(a)
“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
If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import steel racks into a foreign trade zone (FTZ) for use in distribution of steel racks
and/or the production of downstream articles?
(b)
No
II-6.
Yes
Yes
If yes--Identify the firms and the FTZs.
Importer.--Since January 1, 2015, has your firm imported steel racks?
“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 - Steel racks (Preliminary)
II-7.
Page 12
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of steel racks 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.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“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 - Steel racks (Preliminary)
Page 13
Production, shipment, and inventory data.--Continued
II-7.
Quantity (in pounds) and value (in dollars)
Calendar years
Item
2015
January-March
2016
2017
2017
2018
Average production capacity
(quantity) (A)
1
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity)
(L)
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:
.
1
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
January-March
2017
0
2017
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
2018
0
.
0
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
II-8.
Page 14
Channels of distribution.--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.
Quantity (in pounds)
Calendar years
Item
2015
2016
January-March
2017
2017
2018
Channels of distribution:
U.S. shipments:1
To distributors / for
re-sale (M)
To end users / for
installation (N)
1
Sales to retailers should be classified as “end users” to the degree the sales are not merchandise intended for resale.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e., lines M and
N) 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 – D – F – H = zero
("0"), if not revise.
2015
2016
0
January-March
2017
0
2017
0
2018
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
II-9.
Page 15
Rack types.--Please indicate which of the following steel racks your firm produces and sells.
(check as many as appropriate)
Cantilever Rack.--A rack structure comprised primarily of vertical columns, extended bases, horizontal
arms projecting from the face of the columns, and down-aisle bracing between columns. There can be
shelf beams between arms depending on the product being stored. Cantilever columns may be freestanding or overhead tied.
Case-Flow Rack.--A specialized pallet rack structure in which either the horizontal shelf beams support
case-flow lanes or case-flow shelf assemblies are supported by the upright frames. The case-flow lanes or
shelves are installed at a slight pitch permitting multiple-depth case or box storage with loading from one
service aisle and unload or picking from another service aisle.
Drive-In Rack.--A rack structure comprised primarily of vertical upright frames, horizontal support arms,
and horizontal load rails typically used for one-wide by multiple-depth storage. This structure includes an
“anchor section” with horizontal beams supporting the load rails. Loading and unloading within a bay must
be done from the same aisle. A two-way drive-in rack is a special case where back-to-back rows of drive-in
racks are combined into a single entity with a common rear post.
Drive-Through Rack.--A rack structure comprised primarily of vertical upright frames, horizontal support
arms, and horizontal load rails typically used for one-wide by multiple-depth storage. This structure lacks
the ‘anchor section’ found in drive-in racks; therefore, loading and unloading can be accomplished from
both ends of a bay.
Movable-Shelf Rack.--A rack structure comprised primarily of vertical upright frames and horizontal shelf
beams and typically used for one-deep pallet or hand-stack storage. Typically, the locations of a couple of
shelf levels are "fixed" with the location of the in-fill shelves being flexible.
Pallet-Flow Rack.--A specialized pallet rack structure in which the horizontal shelf beams support palletflow lanes. The pallet-flow lanes are typically installed on a slight pitch permitting multiple-depth pallet
storage with loading from one service aisle and unloading from another service aisle.
Pallet Rack.--A rack structure comprised primarily of vertical upright frames and horizontal shelf beams
and typically used for one and two-deep pallet storage.
Pick Modules.--A rack structure comprised primarily of vertical frames and horizontal beams, typically
having one or more platform levels of selective, case-flow, or pallet-flow bays feeding into a central pick
aisle(s) {work platform(s)} supported by the rack structure.
Portable Rack (Stacking Frames).--An assembly, typically with four corner columns, that permits stacking
of one assembly on top of another without applying any additional load to the product being stored on
each assembly.
Push-Back Rack.--A specialized pallet rack structure in which the horizontal shelf beams support pushback lanes comprised of tracks and carts. The push-back lanes are installed on a slight pitch permitting
multiple-depth pallet storage. Loading and unloading are done from the same service aisle by pushing the
pallets back.
Stacker Rack.--A rack structure similar to one of the other rack structures that is serviced by an automated
storage and retrieval machine.
Other steel racks or parts thereof1
1
Please identify:
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
II-10.
Page 16
Rack coatings.--Please indicate the share of quantity of your firm's U.S. shipment (i.e., inclusive
of commercial U.S. shipments, internal consumption, and transfers to related firms) in 2017 by
coating type.
Share of 2017 U.S. Shipments
(percent)
Coating
No coating
Paint
Epoxy coated
Zinc or other galvanized
Other1
Total (should sum to 100.0 percent)
1
II-11.
Please identify:
0.0
.
Employment data.--Report your firm’s employment-related data related to the production of
steel racks 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. For the January to March periods, calculate similarly and divide by 3.
“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
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:
2015
2016
January-March
2017
2017
2018
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 17
II-12.
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.
II-13.
Purchases.--Has your firm purchased steel racks produced in the United States or in other
countries since January 1, 2015? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“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.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in pounds)
Calendar years
Item
2015
2016
January-March
2017
2017
2018
Purchases from U.S. importers of
steel racks from—
China
1
All other sources
Purchases from domestic producers2
Purchases from other sources2
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:
.
1
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
II-14.
Page 18
Imports.--Since January 1, 2015, has your firm imported steel racks?
No
Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-15.
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 - Steel racks (Preliminary)
Page 19
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
jennifer.brinckhaus@usitc.gov).
III-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include steel racks:
2.
Does your firm prepare profit/loss statements for steel racks:
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,
10 Qs,
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 steel racks, 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.).
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 20
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 steel racks, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
Steel racks
Share of sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of steel racks 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 21
No--Continue to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
steel racks that your firm purchases from related suppliers and that are reflected in question III9a. 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 method, as recorded in the firm’s accounting books and records (e.g., related
supplier’s actual cost, cost plus, transfer price to approximate fair market value, etc.)
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 steel racks) in
a manner consistent with your firm’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 22
III-9a. Operations on steel racks.--Report the revenue and related cost information requested below
on the steel racks 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, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact Jennifer Brinckhaus at
(202) 205-3188 before completing this section of the questionnaire.
Quantity (in pounds) and value (in dollars)
Fiscal years ended-Item
2015
2016
January-March
2017
2017
2018
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials
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
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.
1
2
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Page 23
III-9b. 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
III-9c.
No
If 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.
Raw materials.--Please report the share of total raw material costs in 2017 (reported in III-9a)
for the major raw material inputs:
Procurement method
Input
Share of total raw
material costs
(percent)
Primarily
produced by
your firm
Primarily
purchased by
your firm
Steel tubing or long products
Other steel components
Other material inputs1
Total (should sum to 100 percent)
0.0
Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for:
1
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 24
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim 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 III-9a; 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.
Calendar years
2015
Item
2016
January-March
2017
2017
2018
Value (dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the nonrecurring item
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 25
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.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of steel racks. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for steel racks 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 steel racks. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years ended--
Item
Capital expenditures
2015
2016
January-March
2017
2017
2018
1
Research and development expenses2
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 - Steel racks (Preliminary)
Page 26
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, in which case only the interim periods must reconcile. 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.
Fiscal years ended-Reconciliation
2015
2016
January-March
2017
2017
2018
Quantity: Trade data from question II-7
(lines D, F, H, and J) less financial total
net sales quantity data from question III9a, = zero ("0").
0
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
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 27
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 steel racks from China?
No
Yes
If 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 - Steel racks (Preliminary)
Page 28
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 steel racks from China?
No
Yes
If 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 - Steel racks (Preliminary)
Page 29
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
steel racks from China?
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 - Steel racks (Preliminary)
Page 30
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Jon Ruder (202-205-3435,
jonathan.ruder@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
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.--Beam, non-galvanized, 96” length, 4” face, 3 pins connection, 1 5/8” step
Product 2.--Beam, non-galvanized, 120” length, 5” face, 4 pins connection, 1 5/8” step
Product 3.--Frame, non-galvanized, 14 gauge, 3” x 1 5/8” posts, 42” x 120”
Product 4.--Frame, non-galvanized, 14 gauge, 3” x 3” posts, 42” x 192”
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-March 2018, 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 - Steel racks (Preliminary)
Page 31
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.
Product 1
Quantity
Value
(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of shipment
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
2018:
January-March
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 2:
Product 3:
Product 4:
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 32
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
Value data reported in dollars?
Quantity data reported in 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 question II-7 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.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of steel racks
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Other
If other, describe
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Pricing terms.-(a)
What are your firm’s typical sales terms for its U.S.-produced steel racks?
Net 30
days
(b)
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic steel racks usually quoted (check one)?
Delivered
IV-6.
Set
price
lists
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV-5.
Page 33
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 steel
racks in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?
Item
Share of 2017
sales
Long-term
contracts
(multiple
deliveries for
more than 12
months)
%
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
%
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
IV-7.
Page 34
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced steel racks (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
Fixed quantity
and/or price
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
Meet or release
provision
Price
Both
Yes
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 steel racks?
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 - Steel racks (Preliminary)
IV-9.
Page 35
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced steel racks 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 steel racks 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 steel racks 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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Page 36
IV-11. End uses.--List the end uses of the steel racks that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by steel racks and other inputs?
Share of total cost of end use product
accounted for by
End use product
Steel racks
Total
(should sum to
100.0% across)
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-12. Substitutes.--Can other products be substituted for steel racks?
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 steel racks?
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 steel racks has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
increase
Market
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of steel racks since January 1, 2015?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 37
IV-15. Conditions of competition.-(a) Is the steel racks market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to steel racks? 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
steel racks since January 1, 2015?
No
Yes
If yes, describe.
IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply steel racks 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.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 38
IV-17. Raw materials.--How have steel racks raw material prices changed since January 1, 2015?
Fluctuate
with no
clear
Overall
No
Overall
increase change decrease
trend
Item
Explain, noting how raw material price changes
have affected your firm’s selling prices for steel
racks.
Steel tubing or long
products
Other steel
components
Other materials
IV-18. Interchangeability.--Is steel racks 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
Other countries
United States
China
For any country-pair producing steel racks that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 39
IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between steel racks 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
Other countries
United States
China
For any country-pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of steel racks, identify the country-pair and report the advantages or disadvantages
imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
Page 40
IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for steel racks since January 1, 2015. Indicate the share of the quantity of your firm’s
total shipments of steel racks 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
(%)
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Preliminary)
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IV-21. Competition from imports
(a)
Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling steel
racks from China, 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 steel racks to imports of
this product from China?
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: SRACK)
IV-22. 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 - Steel racks (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/steel_racks_china/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: SRACK
• E-mail.—E-mail the MS Word questionnaire to Amelia.Shister@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 | USITCQUESTIONNAIRE |
| Subject | Title 7 investigations |
| Author | Shister, Amelia |
| File Modified | 2018-06-22 |
| File Created | 2018-06-22 |