18-2-3917 US importers' questionnaire

OMB No. 3117-0016/USITC No. 17-2-3917; Expiration Date: 6/30/2020

(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE

SODIUM GLUCONATE, GLUCONIC ACID, AND DERIVATIVE PRODUCTS FROM CHINA

This questionnaire must be received by the Commission by August 6, 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 sodium gluconate, gluconic acid, and derivative products (“GNA products”) from China (Inv. Nos. 701-TA-590 and 731-TA-1397 (Final)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm      

Address      

City       State    Zip Code      

Website      

Has your firm imported GNA 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: GNAP)

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

PART I.—GENERAL INFORMATION

Background. -- This proceeding was instituted in response to a petition filed on November 30, 2017, by PMP Fermentation Products, Inc., Peoria, Illinois. 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/701731/2017/sodium_gluconate_gluconic_acid_and_derivative/final.htm.

GNA Products covered by these investigations are defined as all grades of sodium gluconate, liquid gluconate, and gluconic acid, regardless of physical form (including, but not limited to substrates; solutions; dry granular form or powders, regardless of particle size; or as a slurry). The scope also includes sodium gluconate, liquid gluconate, and gluconic acid that has been blended or is in solution with other product(s) where the resulting mix contains 35 percent or more of sodium gluconate, liquid gluconate, and/or gluconic acid (including glucono delta lactone, in essence dry gluconic acid, commonly referred to as GDL) by dry weight. Sodium gluconate has a molecular formula of NaC₆H₁₁O₇; gluconic acid has a molecular formula of C₆H₁₂O₇; liquid gluconate is a blend of gluconic acid and sodium gluconate in an aqueous solution; and GDL has a molecular formula of C₆H₁₀O₆. Sodium gluconate has a Chemical Abstract Service (CAS) registry number of 527-07-1, and can also be called "sodium salt of gluconic acid" and/or sodium 2, 3, 4, 5, 6-pentahydroxy-hexanoate. Liquid gluconate has CAS registry numbers of 527-07-1, 526-95-4, and 7732-18-5, and can also be called 2, 3, 4, 5, 6-Pentahydroxycaproic acid-hexanoate. Gluconic acid has a CAS registry number of 526-95-4, and can also be called 2, 3, 4, 5, 6-Pentahydroxycaproic Acid. GDL has a CAS registry number of 90-80-2, and can also be called D-Glucono-1,5-lactone. The merchandise covered by the scope of this investigation is currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) at subheadings 2918.16.1000,

2918.16.5010, and 2932.20.5020. Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the merchandise is dispositive.

GNA products are currently imported under statistical reporting numbers 2918.16.10 and 2918.16.50 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.

Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary,

in importing GNA products (as defined above) into the United States from a foreign manufacturer or

through its selling agent.

Reporting of information.‑‑ If information is not readily available from your records, provide carefully prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer, and/or purchaser questionnaire), you need not respond to duplicated questions.

Confidentiality.--The commercial and financial data furnished in response to this questionnaire that reveal the individual operations of your firm will be treated as confidential by the Commission to the extent that such data are not otherwise available to the public and will not be disclosed except as may be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a manner that will reveal the individual operations of your firm; however, general characterizations of numerical business proprietary information (such as discussion of trends) will be treated as confidential business information only at the request of the submitter for good cause shown.

Verification.‑‑ The information submitted in this questionnaire is subject to audit and verification by the Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting documents used in the preparation of the questionnaire response. Please also retain a copy of the final document that you submit.

Release of information.--The information provided by your firm in response to this questionnaire, as well as any other business proprietary information submitted by your firm to the Commission in connection with this proceeding, may become subject to, and released under, the administrative protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and other authorized individuals may temporarily be given access to the information for use in connection with this proceeding or other import-injury proceedings conducted by the Commission on the same or similar merchandise; those individuals would be subject to severe penalties if the information were divulged to unauthorized individuals.

Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you maybe unable to enter in numbers greater than 999 in numeric form fields. The solution to this data entry issue is to temporarily change your operating system’s number formatting to be consistent with the U.S. number formatting system while you complete this form. Detailed instructions on how to resolve this issue is provided at the end of this questionnaire and is available upon request from Robert Casanova (robert.casanova@usitc.gov, 202-708-2719).

D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macro-enabled MS Excel file available for download from the Commission's generic questionnaires webpage (https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding (available on the case page which is linked under the "Background" above) which includes the necessary references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are available within the D-GRIDs tool itself.

I-1. OMB statistics.--Please report below the actual number of hours required and the cost to your firm of completing this questionnaire.

Hours	Dollars
     	     

The questions in this questionnaire have been reviewed with market participants to ensure that issues of concern are adequately addressed and that data requests are sufficient, meaningful, and as limited as possible. Public reporting burden for this questionnaire is estimated to average 40 hours per response, including the time for reviewing instructions, gathering data, and completing and reviewing the questionnaire.

We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing the burden, and any suggestions for improving this questionnaire. Please attach such comments to your response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

I-2. Establishments covered.--Provide the name and address of establishment(s) covered by this questionnaire. If your firm is publicly traded, please specify the stock exchange and trading symbol.

“Establishment”‑‑Each facility of a firm involved in the importation of GNA products, including auxiliary facilities operated in conjunction with (whether or not physically separate from) such facilities.

     

I-3. Ownership.--Is your firm owned, in whole or in part, by any other firm?

No Yes--List the following information

Firm name	Address	Extent of ownership (percent)
     	     	     
     	     	     
     	     	     

I-4. Related importers/exporters.--Does your firm have any related firms, either domestic or foreign, that are engaged in importing GNA products from China into the United States or that are engaged in exporting GNA products from China to the United States?

No Yes--List the following information.

Firm name	Country	Affiliation
     	     	     
     	     	     
     	     	     

I-5. Related producers.--Does your firm have any related firms, either domestic or foreign, that are engaged in the production of GNA products?

No Yes--List the following information.

Firm name	Country	Affiliation
     	     	     
     	     	     
     	     	     
     	     	     
     	     	     
     	     	     

I-6. Importing operations.--Please indicate the nature of your firm’s importing operations on GNA products. More than one answer may be applicable.

Importer of record	Takes title to the imported product(s)	Consignee of the imported products(s)	Customs broker or freight forwarder

I-7. Consignee.--If your firm is an importer of record of GNA products but is not the consignee, please list the consignees below (firm name, address, telephone number, and individual to contact).

Firm name	Address	Contact person and phone number
     	     	     
     	     	     
     	     	     

I-8. FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters GNA products into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate whether your firm imports GNA products under the TIB (temporary importation under bond) program.

“Foreign trade zone” is a designated location in the United States where firms utilize special procedures that allow delayed or reduced customs duty payments on foreign merchandise, as well as other savings. A foreign trade zone must be designed as such pursuant to the rules and procedures set forth in the Foreign-Trade Zones Act.

“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed imports are stored pending their re-export, or release after payment of import duties, taxes, and other charges. A bonded warehouse must be designed as such pursuant to the rules and procedures set forth in 19 U.S.C. § 1555.

“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported merchandise may be entered under certain conditions for a limited time into the United States free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes, etc. that would otherwise be owed on the importation and agrees to export or destroy the merchandise within a specified time or pay liquidated damages. This program is restricted to certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the Harmonized Tariff Schedule of the United States (HTS).

Item	No	Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9. Other trade actions.--To your knowledge, have the products subject to this proceeding been the subject of any other import relief proceedings in the United States or in any other countries?

No Yes–Please specify.

     

PART II.--TRADE AND RELATED INFORMATION

Further information on this part of the questionnaire can be obtained from Robert Casanova (202-708

2719, robert.casanova@usitc.gov). Supply all data requested on a calendar-year basis.

II-1. Contact information.--Please identify the responsible individual and the manner by which Commission staff may contact that individual regarding the confidential information submitted in part II.

Name	     
Title	     
Email	     
Telephone	     

II-2. Changes in operations.--Please indicate whether your firm has experienced any of the following changes in relation to the importation of GNA products since January 1, 2015.

(check as many as appropriate)		(If checked, please describe; leave blank if not applicable)
	Office/warehouse openings	     
	Office/warehouse closings	     
	Relocations	     
	Expansions	     
	Acquisitions	     
	Consolidations	     
	Prolonged shutdowns or importation curtailments	     
	Revised labor agreements	     
	Other (e.g., technology)	     

II-3a. Arranged imports.--Has your firm imported or arranged for the importation of GNA products for delivery after June 30, 2018?

“Arranged imports” are imports for which your firm has placed an order with a foreign supplier for subject merchandise, but delivery of those imports is not scheduled to occur until after the date listed above.

No Yes–Fill out the table below.

Quantity (in 1,000 dry pounds)
Period/Source	Jul-Sep 2018	Oct-Dec 2018	Jan-Mar 2019	Apr-Jun 2019
China	     	     	     	     
Other sources	     	     	     	     

II-3b. Imports in the 12 month period preceding the petition.--Has your firm imported GNA products from any source between November 1, 2016 and October 30, 2017? (i.e., the last two months in 2016 and first ten months in 2017 combined)

No Yes-Report the quantity of such import below by source.

Quantity (in 1,000 dry pounds)
Source	November 2016 through October 2017
China	     
Other sources	     

II-4. Reasons for importing if producer.--If your firm also produces GNA products in the United States, please indicate the reasons for importing this product. If your firm’s reasons differ by source, please elaborate.

     

Definitions

“Imports” –Those products identified for Customs purposes as imports for consumption for which your firm was the importer of record (i.e., was responsible for paying any import duty) or consignee (i.e., to which the merchandise was first delivered).

“Import quantities” –Quantities reported should be net of returns.

“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry, including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the United States).

“U.S. commercial 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.

II-5a. U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories of GNA products imported from China by your firm during the specified periods.

China

Quantity (in 1,000 dry pounds), value (in $1,000)
Item	Calendar years			January-June
	2015	2016	2017	2017	2018
Beginning-of-period inventories (quantity) (A)	     	     	     	     	     
Imports:1 Quantity (B)	     	     	     	     	     
Value (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)	     	     	     	     	     
Channels of distribution: U.S. shipments: To distributors (quantity) (M)	     	     	     	     	     
To end users (quantity) (N)	     	     	     	     	     
1 Please identify the foreign producers, if known:      . 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:      .

II-5a. U.S. imports from China.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.

Reconciliation	Calendar years			January-June
	2015	2016	2017	2017	2018
A + B – D – F – H – J - L = should equal zero ("0") or provide an explanation.1	 0	 0	 0	 0	 0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:       .

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., line D) 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.

Reconciliation item	Calendar years			January-June
	2015	2016	2017	2017	2018
M + N – D – F – H = zero ("0"), if not revise.	 0	 0	 0	 0	 0

II-5b. U.S. shipments by product type: China.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of imports from China by product type. 

China

Quantity (in 1,000 dry pounds) and value (in $1,000)
Product type	Calendar years			January-June
	2015	2016	2017	2017	2018
U.S. shipments of.-- Sodium gluconate Quantity (O)	     	     	     	     	     
Value (P)	     	     	     	     	     
Gluconic acid Quantity (Q)	     	     	     	     	     
Value (R)	     	     	     	     	     
GDL Quantity (S)	     	     	     	     	     
Value (T)	     	     	     	     	     
Liquid gluconate Quantity (U)	     	     	     	     	     
Value (V)	     	     	     	     	     
Blends1 Quantity (W)	     	     	     	     	     
Value (X)	     	     	     	     	     
1 Describe the reported blends:     .

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for US shipments by product type (i.e., lines O through X) in each period equal the quantity and value reported for U.S. shipments (i.e., lines D through I) in part "a" of this question.  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	Calendar years			January-June
	2015	2016	2017	2017	2018
Quantity: O + Q + S + U + W – D – F – H = zero ("0"), if not revise.	 0	 0	 0	 0	 0
Value: P + R + T+ V + X – E – G –I = zero ("0"), if not revise.	 0	 0	 0	 0	 0

II-6a. U.S. imports from all other sources.–Report your firm’s imports and your firm’s shipments and inventories of GNA products imported from all other sources (i.e. all import sources except China) by your firm during the specified periods.

All other sources

(list sources:       )

Quantity (in 1,000 dry pounds), value (in $1,000)
Item	Calendar years			January-June
	2015	2016	2017	2017	2018
Beginning-of-period inventories (quantity) (A)	     	     	     	     	     
Imports:1 Quantity (B)	     	     	     	     	     
Value (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)	     	     	     	     	     
Channels of distribution: U.S. shipments: To distributors (quantity) (M)	     	     	     	     	     
To end users (quantity) (N)	     	     	     	     	     
1 Please identify the foreign producers, if known:      . 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:      .

II-6a. U.S. imports from all other sources.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.

Reconciliation	Calendar years			January-June
	2015	2016	2017	2017	2018
A + B – D – F – H – J - L = should equal zero ("0") or provide an explanation.1	 0	 0	 0	 0	 0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:       .

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 in part "a" of this question. 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 item	Calendar years			January-June
	2015	2016	2017	2017	2018
M + N – D – F – H = zero ("0"), if not revise.	 0	 0	 0	 0	 0

II-6b. U.S. shipments by product type: All other sources.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of imports from all other sources by product type. 

All other sources

Quantity (in 1,000 dry pounds) and value (in $1,000)
Product type	Calendar years			January-June
	2015	2016	2017	2017	2018
U.S. shipments of.-- Sodium gluconate Quantity (O)	     	     	     	     	     
Value (P)	     	     	     	     	     
Gluconic acid Quantity (Q)	     	     	     	     	     
Value (R)	     	     	     	     	     
GDL Quantity (S)	     	     	     	     	     
Value (T)	     	     	     	     	     
Liquid gluconate Quantity (U)	     	     	     	     	     
Value (V)	     	     	     	     	     
Blends1 Quantity (W)	     	     	     	     	     
Value (X)	     	     	     	     	     
1 Describe the reported blends:     .

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for US shipments by product type (i.e., lines O through X) in each period equal the quantity and value reported for U.S. shipments (i.e., lines D through I) in part "a" of this question.  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	Calendar years			January-June
	2015	2016	2017	2017	2018
Quantity: O + Q + S + U + W – D – F – H = zero ("0"), if not revise.	 0	 0	 0	 0	 0
Value: P + R + T+ V + X – E – G –I = zero ("0"), if not revise.	 0	 0	 0	 0	 0

II-7. Other explanations.--If your firm would like to further explain a response to a question in Part II 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.

     

PART III.--PRICING AND MARKET FACTORS

Further information on this part of the questionnaire can be obtained from Fernando Gracia (202-205

2747, Fernando.Gracia@usitc.gov).

III-1. Contact information.--Please identify the responsible individual and the manner by which Commission staff may contact that individual regarding the confidential information submitted in part III.

Name	     
Title	     
Email	     
Telephone	     

PRICE DATA

III-2. This question requests quarterly quantity and value data for your firm’s commercial shipments to unrelated U.S. customers since January 1, 2015 of the following products your firm imported from China:

Product 1.--Sodium gluconate in 50 lb. to 60 lb. bag or kilogram equivalent (i.e., 25 or 30 kg/bag).

Product 2.--Sodium gluconate in 2,000 lb. to 2,500 lb. bag or kilogram equivalent (i.e., 1,000 or 1,250 kg/bag).

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, including those after the sale occurred).

During January 2015-June 2018, did your firm import from China and sell to unrelated U.S. customers any of the above listed products (or any products that were competitive with these products)?

	Yes.--Please complete the following pricing data tables as appropriate.
	No.--Skip to question III-3.

III-2(a). Price data.--Report below the quarterly price data¹ for pricing products² imported from China and sold by your firm.

China

Report data in actual dry pounds (not 1,000s) and actual dollars (not 1,000s).

(Quantity in dry pounds, value in dollars)
Period of shipment	Product 1 Sodium gluconate in 50 lb. to 60 lb. bag		Product 2 Sodium gluconate in 2,000 lb. to 2,500 lb. bag
	Quantity	Value	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	     	     	     	     
April-June	     	     	     	     
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your firm’s U.S. point of shipment. 2 Pricing product definitions are provided on the first page of Part III. Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data. Product 1:       Product 2:      

III-2 (b). Price data checklist.--Please check that the pricing data in question III-2(a) has been correctly reported.

Is the price data reported above:	√ if Yes
In actual dollars (not $1,000)?
In actual dry pounds (not 1,000 dry 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 questions II-5 and II-6 in each year?

III-2(c). 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.

III-3. Price setting.--How does your firm determine the prices that it charges for sales of GNA products (check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.

Transaction by transaction	Contracts	Set price lists	Other	If other, describe
				     

III-4. Discount policy.--Please indicate and describe your firm’s discount policies for GNA products (check all that apply).

Quantity discounts	Annual total volume discounts	No discount policy	Other	Describe
				     

1. Does your company provide rebates to customers who were NOT the company that issued the purchase order and to whom you issued the invoice?

No	Yes	If yes, please describe.
		     

2. In what form(s) are discounts and rebates provided to your customers?

Cash	Account/credit	Other	If rebates and discounts are provided, please describe how they are calculated.
			     

3. Which types of customers receive rebates and discounts?

     

4. For your sales of GNA products imported from China, report the average rebate/discount granted from invoice price in each specified period.

Item	Calendar years			January-June
	2015	2016	2017	2017	2018
Average rebate/discount (percent)	     	     	     	     	     

5. Where are the rebates accounted for in your books and records?

     

III-5. Pricing terms.--

(a) What are your firm’s typical sales terms for GNA products imported from China?

Net 30 days	Net 60 days	2/10 net 30 days	Other	Other (specify)
				     

(b) On what basis are your firm’s prices of imported GNA products from China usually quoted (check one)?

Delivered	F.o.b.	If f.o.b., specify point
		     

III-6. Contract versus spot.--Approximately what share of your firm’s sales of GNA products imported from China 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	Type of sale
	Long-term contracts (multiple deliveries for more than 12 months)		Annual contracts (multiple deliveries for 12 months)		Short-term contracts (multiple deliveries for less than 12 months)		Spot sales (for a single delivery)		Total (should sum to 100.0%)
Share of 2017 sales	     	%	     	%	     	%	     	%	 0.0	%

III-7. Contract provisions.—Please fill out the table regarding your firm’s typical sales contracts for GNA products from China (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	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)
Average contract duration	No. of days	     	365	     
Price renegotiation (during contract period)	Yes
	No
Fixed quantity and/or price	Quantity
	Price
	Both
Meet or release provision	Yes
	No
Not applicable

III-8. Lead times.--What share of your firm’s sales is of GNA products imported from China is 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 GNA products?

Source	Share of 2017 sales		Lead time (Average number of days)
From your firm’s U.S. inventory	     	%	     
From foreign manufacturers’ inventory	     	%	     
Produced to order	     	%	     
Total (should sum to 100.0%)	 0.0	%

III-9. Shipping information.—

(a) What is the approximate percentage of the cost of GNA products imported from China 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) When your firm sells GNA products imported from China, from where is it shipped?

Point of importation Storage facility (check one)

(d) Indicate the approximate percentage of your firm’s sales of GNA products imported from China that are delivered the following distances from your firm’s U.S. point of shipment.

Distance from your firm’s U.S. point of shipment	Share
Within 100 miles	     	%
101 to 1,000 miles	     	%
Over 1,000 miles	     	%
Total (should sum to 100.0%)	 0.0	%

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold GNA products imported from China since January 1, 2015 (check all that apply)?

Geographic area	China
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed, including AK, HI, PR, and VI.

III-11. End uses.--List the end uses of the GNA products that your firm imports. For each end-use product, what percentage of the total cost is accounted for by GNA products and other inputs?

End-use product	Share of total cost of end-use product accounted for by				Total (should sum to 100.0% across)
	GNA products		Other inputs
     	     	%	     	%	 0.0	%
     	     	%	     	%	 0.0	%
     	     	%	     	%	 0.0	%

III-12. Substitutes.--Can other products be substituted for GNA products?

No Yes--Please fill out the table.

Substitute		End-use in which this substitute is used	Have changes in the price of this substitute affected the price for GNA products?
			No	Yes	Explanation
1.	     	     			     
2.	     	     			     
3.	     	     			     

III-13. Demand trends.--Indicate how demand within the United States and outside of the United States (if known) for GNA products has changed since January 1, 2015. Explain any trends and describe the principal factors that have affected these changes in demand.

Market	Overall increase	No change	Overall decrease	Fluctuate with no clear trend	Explanation and factors
Within the United States					     
Outside the United States					     

III-14. Product changes.--Have there been any significant changes in the product range, product mix or marketing of GNA products since January 1, 2015?

No	Yes	If yes, please describe.
		     

III-15. Conditions of competition.—

1. Is the GNA products market subject to business cycles (other than general economy-wide conditions) and/or other conditions of competition distinctive to GNA products?

Check all that apply.		Please describe.
	No	Skip to question III-16.
	Yes-Business cycles (e.g. seasonal business)	     
	Yes-Other distinctive conditions of competition	     

2. If yes, have there been any changes in the business cycles or conditions of competition for GNA products since January 1, 2015?

No	Yes	If yes, describe.
		     

III-16. Supply constraints.--Has your firm refused, declined, or been unable to supply GNA products 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.
		     

III-17. Product quality issues.--Have any of your customers returned GNA products or canceled orders due to quality issues such as product impurities or caking issues, since January 1, 2015?

No	Yes	If yes, please describe.
		     

III-18. Raw materials.--How have GNA products raw material prices changed since January 1, 2015?

Overall increase	No change	Overall decrease	Fluctuate with no clear trend	Explain, noting how raw material price changes have affected your firm’s selling prices for GNA products.
				     

III-19. Interchangeability.--Are GNA products 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 GNA products which is sometimes or never interchangeable, please identify the country-pair and explain the factors that limit or preclude interchangeable use:      

III-20. Factors other than price.--Are differences other than price (e.g., quality, availability, transportation network, product range, technical support, etc.) between GNA products 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 GNA products, identify the country-pair and report the advantages or disadvantages imparted by such factors:      

III-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S. customers for GNA products since January 1, 2015. Indicate the share of the quantity of your firm’s total shipments of GNA products that each of these customers accounted for in 2017.

Customer’s name		City	State	Share of 2017 sales (%)
1	     	     	     	     
2	     	     	     	     
3	     	     	     	     
4	     	     	     	     
5	     	     	     	     
6	     	     	     	     
7	     	     	     	     
8	     	     	     	     
9	     	     	     	     
10	     	     	     	     

III-22. Other explanations.--If your firm would like to further explain a response to a question in Part III 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.

     

Correcting Valid number error messages.--If you are completing a Commission questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than 999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not the MS Word document itself, but the computer from which you are opening up the document).  In the United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.  Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and fractions less than one are delineated with commas (,). The US International Trade Commission’s questionnaires are set-up in the United States with the U.S. number formatting. When this formatting interacts with a computer set to EU number formatting, we believe this may cause this issue. 

The solution to this data entry issue is to temporarily change your operating system’s number formatting to be consistent with the U.S. number formatting system while you complete the questionnaire.

To temporarily change your computer’s number settings to U.S. settings, please do the following (for Microsoft Windows Operating system):

• START

• Control Panel

• Region and Language (under Clock, Language, and Region category)

• Format tab

• Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from $12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with the questionnaire.  When you finish reporting the data then you can close the questionnaire and switch back to Italy settings.

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/sodium_gluconate_gluconic_acid_and_derivative/final.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: GNAP

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

If your firm did not import this product, please fill out page 1, print, sign, and submit a scanned copy to the Commission.

Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the completed questionnaire on parties to the proceeding that are subject to administrative protective order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202-205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR § 207.7). Service of the questionnaire must be made in paper form.