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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3761; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
COLD‐DRAWN MECHANICAL TUBING OF CARBON AND ALLOY STEEL FROM
CHINA, GERMANY, INDIA, ITALY, KOREA, AND SWITZERLAND
This questionnaire must be received by the Commission by October 16, 2017
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 and antidumping duty investigations concerning certain cold‐drawn mechanical
tubing of carbon and alloy steel (“cold‐drawn mechanical tubing”) from China, Germany, India, Italy, Korea, and
Switzerland (Inv. Nos. 701‐TA‐576‐577 and 731‐TA‐1362‐1367 (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 produced cold‐drawn mechanical tubing (as defined on next page) at any time since January 1, 2014?
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: CDMT)
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
Fax:
Email address
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on April 19, 2017, by
ArcelorMittal Tubular Products, Shelby, Ohio; Michigan Seamless Tube, LLC, South Lyon, Michigan; PTC
Alliance Corp., Wexford, Pennsylvania; Webco Industries, Inc., Sand Springs, Oklahoma; and Zekelman
Industries, Inc., Farrell, Pennsylvania. 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/cold_drawn_mechanical_tubing_china_germany_in
dia/final.htm.
Cold‐drawn mechanical tubing covered by these investigations is cold‐drawn mechanical tubing of
carbon and alloy steel, of circular cross‐section, 304.8 mm or more in length, in actual diameters less
than 13 inches (less than 331 mm), and regardless of wall thickness, surface finish, end finish or industry
specification. The subject cold‐drawn mechanical tubing is a tubular product with a circular cross‐
sectional shape that has been cold‐drawn or otherwise cold‐finished after the initial tube formation in a
manner that involves a change in the diameter or wall thickness of the tubing, or both. The subject cold‐
drawn mechanical tubing may be produced from either welded (e.g., electric resistance welded,
continuous welded, etc.) or seamless (e.g., pierced, pilgered or extruded, etc.) carbon or alloy steel
tubular products. It may also be heat treated after cold working (annealed, normalized, quenched and
tempered, stress relieved or finish annealed). Typical cold‐drawing methods for subject merchandise
include, but are not limited to, drawing over mandrel, rod drawing, and sink drawing. Other cold‐
finishing operations that may be used to produce subject merchandise include cold‐rolling and cold‐
sizing the tubing.1
Subject cold‐drawn mechanical tubing is typically certified to meet industry specifications for cold‐drawn
tubing including but not limited to: (1) American Society for Testing and Materials (ASTM) or American
Society of Mechanical Engineers (ASME) specifications ASTM A‐512, ASTM A‐513 Type 3 (ASME SA513
Type 3), ASTM A‐513 Type 4 (ASME SA513 Type 4), ASTM A‐513 Type 5 (ASME SA513 Type 5), ASTM A‐
513 Type 6 (ASME SA513 Type 6), ASTM A‐519 (cold‐finished); (2) SAE International (Society of
Automotive Engineers) specifications SAE J524, SAE J525, SAE J2833, SAE J2614, SAE J2467, SAE J2435,
SAE J2613; (3) Aerospace Material Specification (AMS) AMS T‐6736 (AMS 6736), AMS 6371, AMS 5050,
AMS 5075, AMS 5062, AMS 6360, AMS 6361, AMS 6362, AMS 6371, AMS 6372, AMS 6374, AMS 6381,
AMS 6415; (4) United States Military Standards (MIL) MIL ‐T‐5066 and MIL‐T‐6736; (5) foreign standards
equivalent to one of the previously listed ASTM, ASME, SAE, AMS or MIL specifications including but not
limited to: (a) German Institute for Standardization (DIN) specifications DIN 2391‐2, DIN 2393‐2, DIN
2394‐2; (b) European Standards (EN) EN 10305‐1, EN 10305‐2, EN 10305‐4, EN 10305‐6 and European
national variations on those standards (e.g., British Standard (BS EN), Irish Standard (IS EN) and German
Standard (DIN EN) variations, etc.); (c) Japanese Industrial Standard (JIS) JIS G 3441 and JIS G 3445; and
(6) proprietary standards that are based on one of the above listed standards. The subject cold‐drawn
mechanical tubing may also be dual or multiple certified to more than one standard.
Steel products included in the scope of these investigations are products in which: (1) iron
predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2
percent or less by weight. For purposes of this scope, the place of cold‐drawing determines the country
1
The language in bold is pending the results of a scope clarification request at the Department of Commerce.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 3
of origin of the subject merchandise. Subject merchandise that is subject to minor working in a third
country that occurs after drawing in one of the subject countries including, but not limited to, heat
treatment, cutting to length, straightening, nondestruction testing, deburring or chamfering, remains
within the scope of the investigation. All products that meet the written physical description are within
the scope of these investigations unless specifically excluded or covered by the scope of an existing
order. Merchandise that meets the physical description of cold‐drawn mechanical tubing above is within
the scope of the investigations even if it is also dual‐ or multiple‐certified to an otherwise excluded
specification listed below.
The following products are outside of, and/or specifically excluded from, the scope of these
investigations: ( 1) cold‐drawn stainless steel tubing, containing 10.5 percent or more of chromium by
weight and not more than 1.2 percent of carbon by weight; (2) products certified to one or more of the
following ASTM, ASME or American Petroleum Institute (API) specifications listed below: ASTM A‐53;
ASTM A‐106; ASTM A‐179 (ASME SA 179); ASTM A‐192 (ASME SA 192); ASTM A‐209 (ASME SA 209);
ASTM A‐210 (ASME SA 210); ASTM A‐213 (ASME SA 213); ASTM A‐334 (ASME SA 334); ASTM A‐423
(ASME SA 423); ASTM A‐498; ASTM A‐496 (ASME SA 496); ASTM A‐199; ASTM A‐500; ASTM A‐556;
ASTM A‐565; API SL; and API 5CT; except that any cold‐drawn tubing product certified to one of the
above excluded specifications will not be excluded from the scope if it is also dual‐ or multiple‐certified
to any other specification that otherwise would fall within the scope of these investigations.
The products subject to the investigations are currently imported under the following Harmonized Tariff
Schedule of the United States (HTSUS) statistical reporting numbers: 7304.31.3000, 7304.31.6050,
7304.51.1000, 7304.51.5005, 7304.51.5060, 7306.30.5015, 7306.30.5020, and 7306.50.5030. The HTSUS
provisions above are provided for convenience and customs purposes only. The written description of
the scope of the investigations 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
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
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 4
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 cold‐drawn mechanical tubing and your responses to the
questions in Part I of the producer questionnaire will be provided to the U.S. Department of Commerce,
upon its request, for use in connection with (and only in connection with) its requirement pursuant to
section 702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination
concerning the extent of industry support for the petition requesting this proceeding. Any information
provided to Commerce will be transmitted under the confidentiality and release guidelines set forth
above. Your response to these questions constitutes your consent that such information be provided to
Commerce under the conditions described above.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b. TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
I‐2.
Page 5
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 cold‐drawn mechanical
tubing, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Petition support.‐‐Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China AD
China CVD
Germany AD
India AD
India CVD
Italy AD
Korea AD
Switzerland AD
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
I‐4.
I‐5.
Page 6
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)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing cold‐drawn mechanical tubing from China, Germany,
India, Italy, Korea, and/or Switzerland into the United States or that are engaged in exporting
cold‐drawn mechanical tubing from China, Germany, India, Italy, Korea, and/or Switzerland to
the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
I‐6.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of cold‐drawn mechanical tubing?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, keysha.martinez@usitc.gov). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of cold‐drawn mechanical tubing since January 1, 2014.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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II‐3a. Production using same cold‐drawing machinery.‐‐Please report your firm’s production of
products made on the same equipment and machinery used to produce cold‐drawn mechanical
tubing (i.e., the drawing or mandrel (DOM), rod or sink drawing machinery), and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Overall cold‐drawing capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in short tons)
Calendar years
Item
Overall cold‐drawing capacity
Production of:
Cold‐drawn mechanical tubing (12
inches and over in length)1
2
Other products
Total
1
2
2014
2015
January‐June
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Data entered for production of cold‐drawn mechanical tubing will populate here once reported in question II‐7.
Please identify these products: .
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between cold‐drawn mechanical tubing and
other products using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
(ii)
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.
II‐4.
Tolling.‐‐Since January 1, 2014, has your firm been involved in a toll agreement regarding the
production of cold‐drawn mechanical tubing?
“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 ‐ Cold‐Drawn Mechanical Tubing
II‐5.
Page 11
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce cold‐drawn mechanical tubing in and/or
admit cold‐drawn mechanical tubing into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import cold‐drawn mechanical tubing into a foreign trade zone (FTZ) for use in
distribution of cold‐drawn mechanical tubing and/or the production of downstream
articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2014, has your firm imported cold‐drawn mechanical tubing?
“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
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
II‐7.
Page 12
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of cold‐drawn mechanical tubing 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.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
II‐7.
Page 13
Production, shipment, and inventory data (12 inches and over in length).—Continued
12 inches (304.8 mm) and over in length
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
1
Average production capacity
(quantity) (A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity)
(L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm uses
a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide explanations for
any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
January‐June
Reconciliation
B + C – D – F – H – J – L =
should equal zero ("0") or
provide an explanation.1
1
2014
2015
0
2016
2016
0
0
2017
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
0
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
accurate: .
Page 14
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
II‐8.
Page 15
Channels of distribution (12 inches and over in length).‐‐Report your firm’s commercial U.S.
shipments by channel of distribution and known end use.
Quantity (in short tons)
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
Channels of distribution:
Commercial U.S. shipments:
To distributors1 serving primarily the:
Agricultural sector (M)
Automotive sector (N)
Heavy machinery/industrial sector (O)
Oil and gas sector (P)
To end users in the :
Agricultural sector (R)
Automotive sector (S)
Heavy machinery/industrial sector (T)
Oil and gas sector (U)
2
Other or unknown sector (Q)
2
Other sectors (V)
1
Classify your firms’ commercial U.S. shipments by the intended end use of the product. If product(s) are sold or used in
multiple end use sectors, classify your firms’ commercial U.S. shipments by the primary end use sector that the specific distributor
serves. Please try to minimize the quantity reported as “unknown.”
2
Identify the other sectors: .
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through T) in each time period equal the quantity reported for commercial 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.
Calendar years
Reconciliation
M + N + O + P + Q + R + S + T + U + V–
D = zero ("0"), if not revise.
2014
2015
0
January‐June
2016
0
2016
0
0
2017
0
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
II‐9.
Page 16
U.S. shipments of cold‐drawn mechanical tubing, by type (12 inches and over in length).‐‐
Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal
consumption, and transfers to related firms) of cold‐drawn mechanical tubing.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
U.S. shipments of cold‐drawn mechanical
tubing made from‐‐
Carbon steel welded pipe:
Quantity (U)
Value (V)
Carbon steel seamless pipe:
Quantity (W)
Value (X)
Alloy steel welded pipe:
Quantity (Y)
Value (Z)
Alloy steel seamless pipe:
Quantity (AA)
Value (AB)
2015
January‐June
2016
2016
2017
RECONCILIATION OF SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments in this question equal the quantities and values of US shipments reported in part "a". 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
2014
2015
January‐June
2016
2016
2017
Quantity: U + W + Y + AA– D – F – H
= zero ("0"), if not revise.
0
0
0
0
0
Value: V + X + Z + AB ‐ E – G – I =
zero ("0"), if not revise.
0
0
0
0
0
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 17
II‐10. Employment data (12 inches and over in length).‐‐Report your firm’s employment‐related data
related to the production of cold‐drawn mechanical tubing 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 June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).
“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.
12 inches (304.8 mm) and over in length
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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II‐11. Production, shipment, and inventory data (less than 12 inches in length).—Continued
12 inches (304.8 mm) and over in length
(Quantity in short tons)
Calendar years
Item
Purchases from U.S.
importers1 of cold‐drawn
mechanical tubing from—
China
2014
2015
January‐June
2016
2016
2017
Germany
India
Italy
Korea
Switzerland
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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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
Fax
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include cold‐drawn mechanical
tubing:
2. Does your firm prepare profit/loss statements for cold‐drawn mechanical
tubing:
Yes
No
3. 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
4. Accounting basis: GAAP, cash, tax, or other comprehensive
basis of accounting (specify)
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 cold‐drawn mechanical
tubing, 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 ‐ Cold‐Drawn Mechanical Tubing
III‐4.
Page 20
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 cold‐drawn mechanical tubing, and provide the share of net sales accounted for by
these products in your firm’s most recent fiscal year.
Products
III‐6.
Share of sales
Cold‐drawn mechanical tubing
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of cold‐drawn mechanical tubing 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.
No‐‐Continue to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of cold‐drawn
mechanical tubing that your firm purchases from related suppliers and that are reflected in
question III‐9a. For “Share of total COGS” please report this information by relevant input on
the basis of your most recently completed fiscal year. For “Input valuation” please describe the
basis, as recorded in your company’s own accounting system, of the purchase cost from the
related supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation method utilized (e.g., cost plus, negotiated transfer price to approximate FMV,
etc.)
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
III‐8.
Page 21
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 cold‐drawn
mechanical tubing) in a manner consistent with your firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III‐9a.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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III‐9a. Operations on cold‐drawn mechanical tubing (12 inches and over in length).‐‐Report the
revenue and related cost information requested below on the cold‐drawn mechanical tubing
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 short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐June
2016
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
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.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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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 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.
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual period for which financial results are reported in question III‐9a, please specify all
material (significant) nonrecurring items (charges and gains) in the schedule below, the specific
question III‐9a line item where the nonrecurring items are included, a brief description of the
relevant nonrecurring items, and the associated values (in $1,000), 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.
Fiscal years ended‐‐
2014
2015
January‐June
2016
2016
2017
Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III‐9a.
specific line item in table III‐9a where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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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 cold‐drawn mechanical tubing. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for cold‐
drawn mechanical tubing 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 $1,000)
Fiscal years ended‐‐
Item
2014
2015
1
Total assets (net)
1
III‐13.
2016
Describe
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for cold‐drawn mechanical tubing.
Provide data for your firm’s three most recently completed fiscal years.
Value (in $1,000)
Fiscal years ended‐‐
Item
Capital expenditures
1
Research and development expenses
1
2014
2015
January‐June
2016
2016
2017
2
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 ‐ Cold‐Drawn Mechanical Tubing
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 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.
Full year data
Reconciliation
2014
Quantity: Trade data from question
II‐7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III‐9a, = zero ("0").
2015
0
Partial year periods
2016
0
2016
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial
total net sales value data from
question III‐9a, = zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
2017
0
0
0
0
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 27
If your responses to any of the items in questions III‐15, III‐16, and III‐17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III‐15a. Effects of imports on investment.‐‐Since January 1, 2014, 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 cold‐drawn mechanical tubing from China, Germany, India, Italy, Korea, and/or
Switzerland?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
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
III‐15b. If you responded “yes” to III‐15a, please indicate which market segments any affected
investments were directed toward.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 28
III‐16. Effects of imports on growth and development.‐‐Since January 1, 2014, 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 cold‐drawn mechanical tubing from China,
Germany, India, Italy, Korea, and/or Switzerland?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
cold‐drawn mechanical tubing from China, Germany, India, Italy, Korea, and/or Switzerland?
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 ‐ Cold‐Drawn Mechanical Tubing
Page 29
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202‐205‐
3489, lauren.gamache@usitc.gov).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2014 of the following products produced by your
firm.
Product 1.‐‐ASTM A519 (or equivalent specification) Cold‐Drawn Seamless Tube, Grade 1010‐
1026, outside diameter 5.000 inches, wall thickness 0.990 ‐ 1.010 inch, length 17‐
24 feet, not honed, deburred ends.
Product 2.‐‐ASTM A519 (or equivalent specification) Cold‐Drawn Seamless Tube, Grade 1010‐
1026, outside diameter 4.500 inches, wall thickness 0.990 ‐ 1.010 inch, length 17‐ 24
feet, not honed, deburred ends.
Product 3.‐‐ASTM A513‐5 (or equivalent specification) Cold‐Drawn Over Mandrel Welded Tube,
Grade 1010‐1026, outside diameter 2.500 inches, wall thickness 0.240 ‐ 0.260 inch,
length 17 ‐ 24 feet, not honed, deburred ends.
Product 4.‐‐ASTM A513‐5 (or equivalent specification) Cold‐Drawn Over Mandrel Welded Tube,
Grade 1010‐1026, outside diameter 3.000 inches, wall thickness 0.178 ‐ 0.198 inch,
length 17 ‐ 24 feet, not honed, deburred ends.
Product 5.‐‐ASTM A513‐5 (or equivalent specification) Cold‐Drawn Over Mandrel Welded Tube,
Grade ST52.3, outside diameter 3.750 inches, wall thickness 0.245 ‐ 0.265 inch,
length 17 ‐ 24 feet, not honed, deburred ends.
Product 6.‐‐ASTM A513‐5 (or equivalent specification) Cold‐Drawn Over Mandrel Welded Tube,
Grade ST52.3, outside diameter 4.000 inches, wall thickness 0.245 ‐ 0.265 inch,
length 17 ‐ 24 feet, not honed, deburred ends.
Product 7.‐‐ ASTM A519 Cold Drawn Seamless Tube, Grade 4140/4142, outside diameter 8.000
inches, wall thickness 0.875 inch, length 17.35 feet and 21.68 feet, not honed,
deburred ends.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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Product 8.‐‐ ASTM A519 Cold Drawn Seamless Tube, Grade 4140, outside diameter 9.625 inches,
wall thickness 0.875 inch, length 218.25 inches, not honed, deburred ends.
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
During January 2014‐June 2017, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data tables as appropriate.
No.‐‐Skip to question IV‐3.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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IV‐2(a). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual short tons and actual dollars (not 1,000s).
Period of shipment
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
April‐June
July‐September
October‐December
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
Period of shipment
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
April‐June
July‐September
October‐December
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
(Quantity in short tons, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Quantity
Value
(Quantity in short tons, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value
Product 6
Quantity
Value
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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IV‐2(a). Price data.‐‐Continued.
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 7
Product 8
Quantity
Value
Quantity
Value
Period of shipment
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
April‐June
July‐September
October‐December
2016:
January‐March
April‐June
July‐September
October‐December
2017:
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 IV.
Note.‐‐Please provide a description of your firm’s product, and indicate the exact specification, diameter, and wall thickness of the reported
products in each pricing product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 5:
Product 2:
Product 6:
Product 3:
Product 7:
Product 4:
Product 8:
IV‐2 (b). Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000) and 1,000 short tons?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II‐7 in each year?
IV‐2(c). Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
IV‐3. Price setting.‐‐How does your firm determine the prices that it charges for sales of cold‐drawn
mechanical tubing (check all that apply)? If your firm issues price lists, please submit sample
pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced cold‐drawn mechanical
tubing?
Net 30
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic cold‐drawn mechanical tubing usually
quoted (check one)?
Delivered
Net 60
days
F.o.b.
If f.o.b., specify point
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
IV‐6.
Page 34
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced cold‐
drawn mechanical tubing in 2016 was on a (1) long‐term contract basis, (2) annual contract
basis, (3) short‐term contract basis, and (4) spot sales basis?
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2016
sales
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
IV‐7. Contract provisions.‐‐
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.‐produced cold‐
drawn mechanical tubing (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Short‐term contracts Annual contracts
Long‐term contracts
Typical sales
(multiple deliveries
(multiple
(multiple deliveries for
Item
contract provisions
for less than 12
deliveries for 12
more than 12 months)
months)
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
365
(b) Does your firm sell cold‐drawn mechanical tubing to U.S. purchasers under contracts that were
negotiated outside of the United States?
No Yes
Share of
2016 sales
(percent)
Description (negotiations, provisions
of the contracts, etc.)
End use applications
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
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 cold‐drawn mechanical tubing?
Lead time
(average number
Source
Share of 2016 sales
of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
Page 35
0.0 %
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced cold‐
drawn mechanical tubing that is accounted for by U.S. inland transportation costs?
percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of cold‐drawn mechanical
tubing 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 cold‐drawn mechanical tubing since January 1, 2014 (check all that apply)?
Geographic area
√ if applicable
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.
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U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 36
IV‐11. Differences in transportation.‐‐ Do your firm’s responses to questions IV‐8 through IV‐10 differ
for cold‐drawn mechanical tubing that is less than 12 inches (304.8 mm) in length and cold‐drawn
mechanical tubing that is greater than 12 inches in length?
No
Yes
If yes, describe.
IV‐12. End uses.‐‐
(a)
List the end uses of the cold‐drawn mechanical tubing that your firm manufactures. For
each end‐use product, what percentage of the total cost is accounted for by cold‐drawn
mechanical tubing and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
Cold‐drawn
100.0% across)
End use product
mechanical tubing
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
(b)
Do end use applications for cold‐drawn mechanical tubing less than 12 inches (304.8
mm) in length differ significantly from cold‐drawn mechanical tubing greater than 12
inches in length?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 37
IV‐13. Substitutes.‐‐
(a)
Can other products be substituted for cold‐drawn mechanical tubing?
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 cold‐drawn mechanical
tubing?
No Yes
Explanation
1.
2.
3.
(b)
Do substitutes for cold‐drawn mechanical tubing less than 12 inches (304.8 mm) in
length differ significantly from cold‐drawn mechanical tubing greater than 12 inches in
length?
No
Yes
If yes, describe.
IV‐14. Demand trends.‐‐
(a)
Indicate how demand within the United States and outside of the United States (if
known) for cold‐drawn mechanical tubing has changed since January 1, 2014. Explain
any trends and describe the principal factors that have affected these changes in
demand.
Market
Fluctuate
Overall No
Overall
with no
increase change decrease clear trend
Explanation and factors
Within the United States:
Overall demand
Agricultural sector
Automotive sector
Oil and gas sector
Heavy machinery/industrial
1
Other sectors
Outside the United States
1
Please describe the "other" sectors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 38
IV‐14. Demand trends.‐‐Continued.
(b)
Do demand trends for cold‐drawn mechanical tubing that is less than 12 inches (304.8
mm) in length differ significantly from cold‐drawn mechanical tubing that is greater than 12
inches in length?
No
Yes
If yes, describe.
IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of cold‐drawn mechanical tubing since January 1, 2014?
No
Yes
If yes, please describe and quantify if possible.
IV‐16. Conditions of competition.‐‐
(a) Is the cold‐drawn mechanical tubing market subject to business cycles (other than general
economy‐wide conditions) and/or other conditions of competition distinctive to cold‐
drawn mechanical tubing? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐17.
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
cold‐drawn mechanical tubing since January 1, 2014?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 39
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply cold‐drawn
mechanical tubing since January 1, 2014 (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, been unable to meet timely shipment commitments,
etc.)?
No
Yes
If yes, please describe.
IV‐18. Differences in conditions of competition.‐‐ Do your firm’s responses to questions IV‐16 through
IV‐17 differ for cold‐drawn mechanical tubing that is less than 12 inches (304.8 mm) in length
and cold‐drawn mechanical tubing that is greater than 12 inches in length?
No
Yes
If yes, describe.
IV‐19. Raw materials.‐‐How have cold‐drawn mechanical tubing raw material prices changed since
January 1, 2014?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for cold‐
drawn mechanical tubing.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 40
IV‐20. Interchangeability.‐‐Is cold‐drawn mechanical tubing produced in the United States and in other
countries interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
Germany
India
Italy
Korea
Switzerland
Other
countries
China
Germany
India
Italy
Korea
Switzerland
For any country‐pair producing cold‐drawn mechanical tubing 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 ‐ Cold‐Drawn Mechanical Tubing
Page 41
IV‐21. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between cold‐drawn mechanical
tubing produced in the United States and in other countries a significant factor in your firm’s
sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
Germany
India
Italy
Korea
Switzerland
Other
countries
China
Germany
India
Italy
Korea
Switzerland
For any country‐pair for which factors other than price always or frequently are a significant factor in your firm’s
sales of cold‐drawn mechanical tubing, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
IV‐22. Differences in interchangeability and factors other than price.‐‐ Do your firm’s responses to
questions IV‐20 through IV‐21 differ for cold‐drawn mechanical tubing that is less than 12 inches
(304.8 mm) in length and cold‐drawn mechanical tubing that is greater than 12 inches in length?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 42
IV‐23. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for cold‐drawn mechanical tubing since January 1, 2014. Indicate the share of the
quantity of your firm’s total shipments of cold‐drawn mechanical tubing that each of these
customers accounted for in 2016.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2016
sales
(%)
1
2
3
4
5
6
7
8
9
10
IV‐24. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2014: To avoid losing sales to competitors selling cold‐
drawn mechanical tubing from China, Germany, India, Italy, Korea, and/or Switzerland,
did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2014: Did your firm lose sales of cold‐drawn mechanical
tubing to imports of this product from China, Germany, India, Italy, Korea, and/or
Switzerland?
No
Yes
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 43
IV‐24. Competition from imports‐‐Continued.
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
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: CDMT)
IV‐25. 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 ‐ Cold‐Drawn Mechanical Tubing
Page 44
PART V.—ALTERNATIVE PRODUCT INFORMATION—Cold‐drawn mechanical tubing less than 12 inches
in length that is further processed.
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, keysha.martinez@usitc.gov).
V‐1. Scope‐to‐scope processing operations.‐‐Since January 1, 2014, has your firm purchased in‐
scope cold‐drawn mechanical tubing (either domestic or imported) and further processed those
purchases into other products that still match the definition of cold‐drawn mechanical tubing
("scope‐to‐scope processing")?
No
Yes
If yes—Please describe the nature and extent of the following items in
relation to your firm's scope‐to‐scope processing operations in the United
States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Costs and activities
V‐2.
Scope‐to‐scope processing operations' complexity and importance.‐‐On a scale of 1 to 5, please
provide your firm's subjective opinion as to the complexity, intensity, and importance of scope‐
to‐scope processing activities as they relate to your firm's overall operations. 1 being minimally
complex, intense or important. 5 being extremely complex, intense, and important.
1:
Minimally complex,
intense, and
important
2
3
4
Please describe the reason for your rating.
5:
Extremely complex,
intense, and
important
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐3.
Page 45
Your sales of further processed scope merchandise.‐‐Do your customers consider the
product(s) they purchase from your firm to be "cold‐drawn mechanical tubing"?
V‐4.
Yes
No
If No—Please describe the how your customers perceive the goods they are
purchasing from your firm.
Production, shipment, and inventory data (less than 12 inches in length)‐‐ Report your firm’s
production capacity, production, shipments, and inventories related to the production of cold‐
drawn mechanical tubing less than 12 inches in length in its U.S. establishment(s) during the
specified periods.
Less than 12 inches (304.8 mm) in length
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
1
Average production capacity
(quantity) (A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity)
(L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm uses
a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐4.
Page 46
Production, shipment, and inventory data (less than 12 inches in length).—Continued
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
January‐June
Reconciliation
2014
B + C – D – F – H – J – L =
should equal zero ("0") or
provide an explanation.1
2015
0
2016
2016
0
0
2017
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
V‐5.
Channels of distribution (less than 12 inches in length).‐‐Report your firm’s commercial U.S.
shipments by channel of distribution and known end use.
Quantity (in short tons)
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
Channels of distribution:
Commercial U.S. shipments:
To distributors1 serving primarily the:
Agricultural sector (M)
Automotive sector (N)
Heavy machinery/industrial sector (O)
Oil and gas sector (P)
To end users in the :
Agricultural sector (R)
Automotive sector (S)
Heavy machinery/industrial sector (T)
Oil and gas sector (U)
2
Other or unknown sector (Q)
2
Other sectors (V)
1
Classify your firms’ commercial U.S. shipments by the intended end use of the product. If product(s) are sold or used in
multiple end use sectors, classify your firms’ commercial U.S. shipments by the primary end use sector that the specific distributor
serves. Please try to minimize the quantity reported as “unknown.”
2
Identify the other sectors: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 47
V‐5. Channels of distribution (less than 12 inches in length).‐‐Continued
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through T) in each time period equal the quantity reported for commercial 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.
Calendar years
Reconciliation
2014
M + N + O + P + Q + R + S + T + U + V–
D = zero ("0"), if not revise.
2015
0
January‐June
2016
0
2016
0
2017
0
0
V‐6.
U.S. shipments of cold‐drawn mechanical tubing, by type (less than 12 inches in length).‐‐
Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal
consumption, and transfers to related firms) of cold‐drawn mechanical tubing.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
U.S. shipments of cold‐drawn mechanical
tubing made from‐‐
Carbon steel welded pipe:
Quantity (U)
Value (V)
Carbon steel seamless pipe:
Quantity (W)
Value (X)
Alloy steel welded pipe:
Quantity (Y)
Value (Z)
Alloy steel seamless pipe:
Quantity (AA)
Value (AB)
2015
January‐June
2016
2016
2017
RECONCILIATION OF SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments in this question equal the quantities and values of US shipments reported in part "a". 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
2014
2015
January‐June
2016
2016
2017
Quantity: U + W + Y + AA– D – F – H
= zero ("0"), if not revise.
0
0
0
0
0
Value: V + X + Z + AB ‐ E – G – I =
zero ("0"), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐7.
Page 48
Employment data (less than 12 inches in length).‐‐Report your firm’s employment‐related data
related to the production of cold‐drawn mechanical tubing less than 12 inches in length 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 June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).
“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.
Less than 12 inches (304.8 mm) in length
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐8.
Page 49
Purchases (less than 12 inches in length).‐‐Other than direct imports, has your firm otherwise
purchased cold‐drawn mechanical tubing since January 1, 2014?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐9.
Page 50
Operations on cold‐drawn mechanical tubing (LESS THAN 12 INCHES IN LENGTH).‐‐Report the
revenue and related cost information requested below on the cold‐drawn mechanical tubing
(less than 12 inches in length) 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 specified interim periods below.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2014
2015
January‐June
2016
2016
2017
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Cost of goods sold (COGS):
Purchased cold‐drawn mechanical tubing –
domestically produced
Purchased cold‐drawn mechanical tubing –
subject imports
Purchased cold‐drawn mechanical tubing –
non‐subject imports
Total net sales quantities
2
Net sales values:
Commercial sales
Total net sales values
3
Total purchased cold‐drawn mechanical
tubing
Other raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
Page 51
V‐10. Reconciliation of trade and financials.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in V‐4 equal the quantities and values reported total net sales in V‐5 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.
Full year data
Reconciliation
2014
Quantity: Trade data from question
V‐4 (lines D, F, H, and J) less financial
total net sales quantity data from
question V‐9, = zero ("0").
Partial year periods
2015
0
2016
0
2016
0
Value: Trade data from question V‐4
(lines E, G, I, and K) less financial
total net sales value data from
question V‐9, = zero ("0").
0
0
0
Do these data in question V‐4 reconcile with data in question V‐5?
Yes
No
2017
0
0
0
0
If no, please explain.
V‐11. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of cold‐drawn mechanical tubing less than 12 inches in
length. If your firm does not maintain some or all of the specific asset information necessary to
calculate total assets for cold‐drawn mechanical tubing 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 $1,000)
Fiscal years ended‐‐
Item
1
Total assets (net)
1
Describe
2014
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire ‐ Cold‐Drawn Mechanical Tubing
V‐12.
Page 52
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for cold‐drawn mechanical tubing less
than 12 inches in length. Provide data for your firm’s three most recently completed fiscal
years, and specified interim periods below.
Value (in $1,000)
Fiscal years ended‐‐
Item
Capital expenditures
1
Research and development expenses2
1
2014
2015
January‐June
2016
2016
2017
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 ‐ Cold‐Drawn Mechanical Tubing
Page 53
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/701731/2017/cold_drawn_mechanical_tubing_ch
ina_germany_india/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: CDMT
• E‐mail.—E‐mail the MS Word questionnaire to keysha.martinez@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 (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producers--Cold Drawn Mechanical Tubing (F) |
| Author | keysha.martinez |
| File Modified | 2017-09-21 |
| File Created | 2017-09-21 |