17-3-3759 US purchasers' questionnaire

OMB No. 3117-0016/USITC No. 17-3-3759; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ QUESTIONNAIRE
TOOL CHESTS AND CABINETS FROM CHINA AND VIETNAM
This questionnaire must be received by the Commission by October 11, 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 investigations concerning tool chests and cabinets from China and
Vietnam (Inv. Nos. 701-TA-575 and 731-TA-1360-1361 (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 possession (19 U.S.C.
§ 1333(a)). Further information on this questionnaire can be obtained from Amelia Preece (303-205-3250,
amelia.preece@usitc.gov).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased tool chests and cabinets; tool chests and cabinets not prepackaged for retail sale; or
industrial tool chests and cabinets (as defined on next page) from any country 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: TOOL)
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
submitting 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. Purchasers’ Questionnaire - Tool Chests and Cabinets

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on April 11, 2017, by
Waterloo Industries Inc., Sedalia, Missouri. 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/tool_chests_and_cabinets_china_and_vietnam/fina
l.htm.
Tool chests and cabinets All metal tool chests and cabinets, including top chests, intermediate chests,
tool cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for all
other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 10 inches but not exceeding 24 inches; and
(5) prepackaged for retail sale.
For purposes of this scope, the width parameter applies to each individual unit, i.e., each individual top
chest, intermediate top chest, tool cabinet, side cabinet, storage unit, mobile work bench, and work
station.
Prepackaged for retail sale means the units are packaged in a cardboard box or other container suitable
for retail display and sale. Subject tool chests and cabinets are covered whether imported in assembled
or unassembled form. Subject merchandise includes tool chests and cabinets produced in China or
Vietnam but assembled, prepackaged for sale, or subject to other minor processing in a third country
prior to importation into the United States. Similarly, it would include tool chests and cabinets produced
in China or Vietnam that are later found to be assembled, prepackaged for sale, or subject to other
minor processing after importation into the United States.
Subject tool chests and cabinets may also have doors and shelves in addition to drawers, may have
handles (typically mounted on the sides), and may have a work surface on the top. Subject tool chests
and cabinets may be uncoated (e.g., stainless steel), painted, powder coated, galvanized, or otherwise
coated for corrosion protection or aesthetic appearance.
Subject tool chests and cabinets may be packaged as individual units or in sets. When prepackaged in
sets, they typically include a cabinet with one or more chests that stack on top of the cabinet. Tool
cabinets act as a base tool storage unit and typically have rollers, casters, or wheels to permit them to
be moved more easily when loaded with tools. Work stations and work benches are tool cabinets with a
work surface on the top that may be made of rubber, plastic, metal, wood, or other materials.
Top chests are designed to be used with a tool cabinet to form a tool storage unit. The top chests may
be mounted on top of the base tool cabinet or onto an intermediate chest. They are often packaged as a
set with tool cabinets or intermediate chests, but may also be packaged separately. They may be
packaged with mounting hardware (e.g. bolts) and instructions for assembling them onto the base tool
cabinet or onto an intermediate tool chest which rests on the base tool cabinet. Smaller top chests
typically have handles on the sides, while the larger top chests typically lacks handles. Intermediate tool
chests are designed to sit on top of the floor standing tool cabinet and to be used underneath the top
tool chest. Although they may be packaged or used separately from the tool cabinet, intermediate

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chests are designed to be used in conjunction with tool cabinets. Intermediate chests typically do not
have handles, but the intermediate and top chests may have the capability of being bolted together.
Side cabinets are designed to be bolted or otherwise attached to the side of the base storage cabinet to
expand the storage capacity of the base tool cabinet.
Subject tool chests and cabinets also may be packaged with a tool set included. Packaging a subject tool
chest and cabinet with a tool set does not remove an otherwise covered subject tool chest and cabinet
from the scope. When this occurs the tools are not part of the subject merchandise.
All tool chests and cabinets that meet the above definition are included in the scope unless otherwise
specifically excluded.
Excluded from the scope of the investigations are tool boxes, chests, and cabinets with bodies made of
plastic, carbon fiber, wood, or other non-metallic substances. Also excluded from the scope of the
investigations are industrial grade steel tool chests and cabinets. The excluded industrial grade steel tool
chests and cabinets are those:
(1) having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047 inches or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each width
range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

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Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370
Also excluded from the scope of the investigations are service carts. The excluded service carts have all
of the following characteristics:
(1) casters, wheels, or other similar devices which allow the service cart to be rolled from place
to place;
(2) a flat top or flat lid on top of the unit that opens;
(3) a space or gap between the casters, wheels, or other similar devices, and the bottom of
the enclosed storage space (e.g., drawers) of at least 10 inches; and
(4) a total unit height, including casters, of less than 48 inches.
Also excluded from the scope of the investigations are work benches having each of the following
characteristics:
(1) a solid top working surface;
(2) no drawers, one drawer, or two drawers in a side-by side configuration; and
(3) the unit is supported by legs and the unit has no solid front, side, or back panels enclosing
the body of the unit.
Also excluded from the scope of the investigations are metal filing cabinets that are configured to hold
hanging file folders and are classified in the Harmonized Tariff Schedule of the United States (HTSUS) at
subheading 9403.10.0020.
Merchandise subject to the investigation is classified under HTSUS categories 9403.20.0021,
9403.20.0026, 9403.20.0030 and 7326.90.86881 but may also be classified under HTSUS category
7326.90.3500. While HTSUS subheadings are provided for convenience and Customs purposes, the
written description of the scope of this investigation is dispositive.

1

On January 1, 2017, HTSUS subheading 7326.90.85 was re-designated as HTSUS subheading 7326.90.86.

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Other tool chests and cabinets.--Other tool chests and cabinets include the following items:
1. Tool chests and cabinets not prepackaged for retail sale
This includes all metal tool chests and cabinets, including top chests, intermediate chests, tool
cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for
all other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 1 0 inches but not exceeding 24 inches; and
(5) not prepackaged for retail sale.
2. Industrial tool chests and cabinets
The excluded industrial grade steel tool chests and cabinets are those:
(1) Having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047" or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each
width range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

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Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370
Purchaser.--Any firm engaged, either directly or through a parent company or subsidiary, in purchasing
tool chests and cabinets from another firm that produces, imports, or otherwise distributes tool chests
and cabinets.
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.

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
I-1.

Page 7

OMB statistics.--Please report 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
25 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 your U.S. establishment(s) covered
by this questionnaire, if different from that listed on the cover page. 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 purchase of tool chests and cabinets,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
I-3.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name

I-4.

Yes--List the following information.
Address

Extent of ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, which import tool chests and cabinets into the United States or which export tool chests
and cabinets to the United States?
No
Firm name

I-5.

Page 8

Yes--List the following information.
Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
produce tool chests and cabinets?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

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PART II.--PURCHASES
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this questionnaire.
Name
Title
Email
Telephone
Fax
Purchases.—Report your firm’s total U.S. purchases of tool chests and cabinets. Please report
separately for your purchases from U.S. producers and importers, and your purchases for which
your firm was the importer of record.

II-1.

2014

2015

Item

2016

Quantity (in units)

Purchases of tool chests and cabinets
produced in—
United States
China
Vietnam
All other countries1
Sources unknown
Total purchases

0

0

0

0

0

0

Imports of tool chests and cabinets
from—
China
Vietnam
All other countries1
Total imports
1

Please identify these countries:

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
II-2.

Page 10

Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of
tool chests and cabinets from different sources have changed since January 1, 2014.

Did not
Source of purchases purchase Decreased Increased Constant Fluctuated

Explanation for trend

United States
China
Vietnam
All other countries
Sources unknown
II-3.

Purchases from one country only.--If your firm has purchased tool chests and cabinets from
only one country, please explain the reasons for doing so.

II-4.

Supplier identification.--Please list your firm’s FIVE largest suppliers for tool chests and cabinets
since January 1, 2014. Also, provide the share of the quantity of your firm’s total purchases of
tool chests and cabinets that each of these suppliers accounted for in 2016.

No.

Supplier’s name

City and state

Share of quantity of
2016 purchases

1

%

2

%

3

%

4

%

5

%

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

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PART III.--MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III-1.

Firm type.--Which of the following best describes your firm as a purchaser of tool chests and
cabinets (check all that apply)?
End user

Retailer

Distributor

Other

Describe other

If your firm is a distributor of tool chests and cabinets, please answer questions III-2 and III-3.
III-2.

Competition for sales.--Does your firm compete for sales to customers with the manufacturers
or importers from which your firm purchases tool chests and cabinets?
No

III-3.

Yes

If yes, please describe.

Types of customers.--What are the major types of consumers to which your firm sells tool chests
and cabinets?

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
III-4.

Page 12

Substitutes.--Can other products be substituted for tool chests and cabinets?
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 tool chests and cabinets?
No Yes

Explanation

1.
2.
3.
III-5.

Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for tool chests and cabinets has changed since January 1, 2014. Explain any
trends and describe the principal factors that have affected these changes in demand.

Overall
increase

Market

No
change

Overall
decrease

Fluctuate
with no
clear trend

Explanation and factors

Within the United States
Outside the United States
III-6.

Country preferences.--Do you or your customers ever specifically order tool chests and cabinets
from one country in particular over other possible sources of supply?
No

Yes

If yes, identify the countries and explain.

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
III-7.

Importance of purchasing domestic product.--Please fill out the table below, estimating the
percentage of your firm’s total 2016 purchases of tool chests and cabinets that required tool
chests and cabinets produced in the United States.

Purchases that did not require domestic product
Purchases that were required by law or regulation to be domestic product
(e.g., government purchases under “Buy American” provisions)
Purchases that were not required by law or regulation, but were required by
your customers to be domestic product
Purchases that were required to be domestic product for other reasons
(explain:
)
Total (should sum to 100.0%)
III-8.

Page 13

Estimated percentage of
your firm’s total 2016
purchases of tool chests
and cabinets
%
%
%
%
0.0 %

Conditions of competition.-(a)

Is the tool chests and cabinets market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to tool
chests and cabinets?

Check all that apply.

Please describe.

No

Skip to question III-9.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b)

Have there been any changes in the business cycles or conditions of competition for tool
chests and cabinets since January 1, 2014?
No

Yes

If yes, describe.

(c) Has competition from Sears changed since January 1, 2014 in a way that affects competition
within the tool chests and cabinets market?
No

Yes

If yes, describe.

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
III-9.

Page 14

Decisions based on producer and country-of-origin.--How often does your firm, and if known,
do your customers, make purchasing decisions involving tool chests and cabinets based on its
producer or country of origin?
Always

Usually

Sometimes

Never

If at least sometimes, explain.

Decision based on producer
Your firm
Your customers
Decision based on country of origin
Your firm
Your customers
III-10. Availability of supply.--Has the availability of tool chests and cabinets in the U.S. market
changed since January 1, 2014?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
U.S.-produced product
Subject imports
Nonsubject imports

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III-11. Supply constraints.--Has any firm refused, declined, or been unable to supply your firm with
tool chests and cabinets 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.

III-12. Availability of specific product types.--Are certain grades/types/sizes of tool chests and
cabinets only available from certain country sources?
No

Yes

If yes, please identify the countries and the grade/type/size.

III-13. Purchasing frequency.-(a)

How frequently does your firm make purchases of tool chests and cabinets (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Has this purchasing frequency changed since January 1, 2014?
No

Yes

If yes, please describe.

III-14. Number of suppliers contacted.--How many suppliers does your firm generally contact before
making a purchase? Between
and
firms

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

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III-15. Supplier negotiations.--Does your firm’s purchases of tool chests and cabinets usually involve
negotiations between supplier and purchaser?

No

Yes

If yes, explain the factors your firm generally negotiates and note
whether your firm quotes competing prices during negotiations.

III-16. Change in suppliers.--Has your firm changed suppliers since January 1, 2014?

No

Yes

If yes, please list the supplier(s), whether the firm was added or
dropped, and the reasons for the change.

III-17. New suppliers.--Are you aware of any new suppliers, either foreign or domestic, that have
entered the market since January 1, 2014?
No

Yes

If yes, please identify the firms.

III-18. Supplier qualification.--Do you require your suppliers to be or to become certified or qualified
to sell tool chests and cabinets to your firm?
If yes, provide the following information.
• The number of days to qualify a new supplier.
• A general description of the certification or qualification process. Also, a brief
description of the factors that you consider when qualifying a new supplier (e.g., quality
of product, reliability of supplier, etc.).

No

Yes

Number
of days Process and factors

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III-19. Failure to certify.--Since January 1, 2014, have any domestic or foreign producers failed in their
attempts to certify or qualify their tool chests and cabinets with your firm or have any producers
lost their approved status?

No

Yes

If yes, please identify these firms, the countries where they are located,
and the reasons why they failed the certification/qualification.

III-20. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase tool chests and cabinets (examples include
availability, extension of credit, contracts, price, quality, range of supplier’s product line,
traditional supplier, brand, etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

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III-21. Purchasing factors.--Please rate the importance of the following factors in your firm’s
purchasing decisions for tool chests and cabinets.

Factor

Very
important

Somewhat
important

Not
important

Availability
Brand
Customization of product for your firm
Delivery terms
Delivery time
Discounts offered
Extension of credit
Innovative, high-tech features
Minimum quantity requirements
Packaging
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs
III-22. Quality characteristics.--What characteristics does your firm consider when determining the
quality of tool chests and cabinets?

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U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

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III-23. Minimum quality.--How often does tool chests and cabinets from the following countries meet
minimum quality specifications for your uses or your customers’ uses?

Source

Always

Usually

Sometimes

Rarely or
never

Don’t
know

United States
China
Vietnam
Other
III-24. Frequency of decisions based on price.--How often does your firm purchase the tool chests and
cabinets that is offered at the lowest price?
Always

Usually

Sometimes

Never

III-25. Choice of product not based on price.--If you purchased tool chests and cabinets from one
country source although a comparable product was available from another country source at a
lower price, please explain your reasons for doing so (please specify by country).

III-26. Price leaders.--A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that is followed by other firms, or (2) one or more firms that have a
significant impact on prices. A price leader is not necessarily the lowest-priced supplier.
Please list the names of any firms you considered price leaders in the tool chests and cabinets
market since January 1, 2014.
Firm(s)

Describe how the firm(s) exhibited price leadership

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III-27. Brand purchases.—
(a) Please list the brands of tool chests and cabinets that your firm purchases.

(b) Please list what your firm requires for a producer or importer to be eligible to produce for
your brand.

(c) Please estimate the number of days it would take for a producer become eligible to
produce your brand.
to

days

(d) Describe the importance of branding in sales of tool chests and cabinets for your
customers.

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III-28. Purchasing subject imports rather than domestic products.—
(a)

Since January 2014, did your firm purchase imports of tool chests and cabinets from
China and Vietnam instead of U.S.-produced tool chests and cabinets? Respond for
each subject country.

Source

Yes
(also respond to parts (b) and (c))

No
(If “No” for all countries, skip to next
question)

China
Vietnam
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

China
Vietnam
(c)

If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?

Source

China
Vietnam

Yes

If Yes, estimate the quantity
of imports purchased instead
of domestic product since
January 2014
(in units)

No

If No, please indicate the
reason your firm purchased
imports instead of domestic
product

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

Page 22

III-29. U.S. producers and import competition.—
(a)

Since January 1, 2014, in connection with a sale or offer to sell tool chests and cabinets
to your firm, did U.S. producers reduce their prices of domestically produced tool chests
and cabinets in order to compete with lower-priced imports of tool chests and cabinets
from the subject countries? Respond for each subject country.
Source

Yes (also respond to
question part (b))

No (If “No” for all countries,
skip to next question)

Don’t know

China
Vietnam
(b)

If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices, and any additional explanations, such as
timing (e.g., months/years), frequency of price reductions, or other market/competitive
factors.

Source

Estimated
reduction in U.S.
prices
(percent)

China

%

Vietnam

%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

Page 23

PART IV.—PRODUCT COMPARISONS
IV-1.

Country knowledge.--Please indicate the countries of origin for tool chests and cabinets for
which your firm has actual marketing/pricing knowledge.
United
States

IV-2.

China

Vietnam

Other
countries

Other countries (specify)

Interchangeability.--Are tool chests and cabinets 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

Vietnam

Other countries

United States
China
Vietnam
For any country-pair producing tool chests and cabinets which is sometimes or never
interchangeable, please identify the country-pair and explain the factors that limit or preclude
interchangeable use:

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
IV-3.

Page 24

Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, brand etc.) between tool chests and
cabinets produced in the United States and in other countries a significant factor in your firm’s
purchases 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

Vietnam

Other countries

United States
China
Vietnam
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of tool chests and cabinets, identify the country-pair and report
the advantages or disadvantages imparted by such factors:

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
IV-4.

Page 25

Factor country comparisons.--For the factors listed below, please rate how tool chests and
cabinets produced in each country you identified in your response to the first question in Part IV
compares with tool chests and cabinets produced in each of the other countries you identified.

If you are unfamiliar with the product from a particular country, please leave the boxes for those
country comparisons blank.

Inferior

Comparable

Product from
China
compared to
product from
Vietnam

Superior

Inferior

Comparable

Product from
United States
compared to
product from
Vietnam

Superior

Inferior

Comparable

Factor

Superior

Product from
United States
compared to
product from
China

Availability
Brand
Customization of product for your firm
Delivery terms
Delivery time
Discounts offered
Extension of credit
Innovative, high-tech features
Minimum quantity requirements
Packaging
Price1
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs1
1

A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
IV-4.

Page 26

Continued.

If you are unfamiliar with the product from a particular country, please leave the boxes for those
country comparisons blank.

Inferior

Comparable

Product from
Vietnam
compared to
product from
Nonsubject
countries

Superior

Inferior

Comparable

Product from
China
compared to
product from
Nonsubject
countries

Superior

Inferior

Comparable

Factor

Superior

Product from
United States
compared to
product from
Nonsubject
countries

Availability
Brand
Customization of product for your firm
Delivery terms
Delivery time
Discounts offered
Extension of credit
Innovative, high-tech features
Minimum quantity requirements
Packaging
Price1
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs1
1

A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

Page 27

PART V – ALTERNATIVE PRODUCT
Other tool chests and cabinets include the following items:
1. Tool chests and cabinets not prepackaged for retail sale.
This includes all metal tool chests and cabinets, including top chests, intermediate chests, tool
cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for
all other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 1 0 inches but not exceeding 24 inches; and
(5) not prepackaged for retail sale.
2. Industrial tool chests and cabinets.
The excluded industrial grade steel tool chests and cabinets are those:
(1) Having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047" or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each
width range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370

Page 28

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 29

Comparability of in-scope tool chests and cabinets to out-of-scope industrial tool chests and
cabinets -- For each of the following factors, indicate whether in-scope tool chest and cabinets
compared to select out-of-scope products are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
(b) Interchangeability.--The ability to substitute the products in the in the same application.

Product-pair
In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 30

Comparability of in-scope tool chests and cabinets to select out-of-scope products--Continued
(c) Manufacturing facilities, production processes, and production employees.--Whether the
products are manufactured in the same facilities, from the same inputs, on the same
machinery and equipment, and using the same employees.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).

Product-pair
In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 31

Comparability of in-scope tool chests and cabinets to select out-of-scope products--Continued
(e) Customer and producer perceptions.--Perceptions as to the differences and/or similarities
in the products in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and producer perceptions:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
prices:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
V-2.

Purchases.--Report your firm’s total U.S. purchases of industrial tool chests and cabinets. Please
report your purchases from U.S. producers and importers.
2014

2015

Item

2016

Quantity (in units)

Purchases of industrial tool chests and
cabinets produced in—
United States
Imports (all sources)
Total industrial purchases

0

0

0

0

0

0

Purchases and /or imports of other tool
chests and cabinets not prepackaged
for retail sale produce in –
United States
Imports (all sources)
Total other purchases

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

Page 32

PART VI.—ADDITIONAL INFORMATION
VI-1.

Other explanations.--If your firm would like to further explain a response to any question that
did not provide a narrative response box, please note the question number and the explanation
in the space provided below.

Business Proprietary
U.S. Purchasers’ Questionnaire - Tool Chests and Cabinets

Page 33

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/tool_chests_and_cabinets_china_a
nd_vietnam/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: TOOL

• E-mail.—E-mail the MS Word questionnaire to Amelia Preece (303-205-3250,
amelia.preece@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 dropbox 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 nonencrypted 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 purchase this product, please fill out page 1, print, sign, and submit a scanned
copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire your firm submits (see
19 CFR § 207.7). Service of the questionnaire must be made in paper form.