20-3-4179 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4179; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ QUESTIONNAIRE
CERTAIN COLLATED STEEL STAPLES FROM CHINA
This questionnaire must be received by the Commission by March 20, 2020
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 collated steel staples (“CCS
staples”) from China (Inv. Nos. 701-TA-626 and 731-TA-1452 (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)).Further information on this questionnaire can be obtained from Craig Thomsen (202-205-3226,
craig.thomsen@usitc.gov).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased or imported for own use or retail sale CCS staples (as defined on next page) from any
source (domestic or foreign) at any time since January 1, 2017?

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: CCS)
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

Signature

Phone

Email address

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on June 6, 2019, by Kyocera
Senco Industrial Tools, Inc., Cincinnati, Ohio. 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/dumping. Questionnaires and other
information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/certain_collated_steel_staples_china/final.htm.
Certain Collated Steel Staples (“CCS staples”) covered by these investigations are made from steel wire
having a nominal diameter from 0.0355 inch to 0.0830 inch, inclusive, and have a nominal leg length
from 0.25 inch to 3.0 inches, inclusive, and a nominal crown width from 0.187 inch to 1.125 inch,
inclusive.
Certain collated steel staples may be manufactured from any type of steel, and are included in the scope
of this investigation regardless of whether they are uncoated or coated, and regardless of the type or
number of coatings, including but not limited to coatings to inhibit corrosion. Certain collated steel
staples may be collated using any material or combination of materials, including but not limited to
adhesive, glue, and adhesive film or adhesive or paper tape.
Certain collated steel staples are generally made to American Society for Testing and Materials (ASTM)
specification ASTM F1667-18a, but can also be made to other specifications.
Excluded from the scope of these investigations are any carton-closing staples covered by the scope of
the existing antidumping duty order on Carton-Closing Staples from the People's Republic of China. See
Carton-Closing Staples from the People's Republic of China: Antidumping Duty Order, 83 FR 20792 (May
8, 2018).
Certain collated steel staples are currently imported under statistical reporting number 8305.20.0000 of
the Harmonized Tariff Schedule of the United States (HTSUS). While the HTSUS subheading and ASTM
specification are provided for convenience and for customs purposes, the written description of the
subject merchandise is dispositive.
Purchaser.--Any firm engaged, either directly or through a parent company or subsidiary, in purchasing
CCS staples from another firm that produces, imports, or otherwise distributes CCS staples.
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

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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 - CCS Staples (Final)
I-1a.

Page 4

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 response.
“Establishment”--Each facility of a firm involved in the purchase of CCS staples, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

I-1b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-1c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
.
Lead attorney(s):

I-2.

.

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

Yes--List the following information.
Address

Extent of ownership
(percent)

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)
I-3.

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

I-4.

Page 5

Yes--List the following information.
Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
produce CCS staples?
No
Firm name

Yes--List the following information.
Country

Affiliation

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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
II-1.

Purchases and imports.--Report separately your firm’s domestic purchases and imports of CCS
staples.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2017

2018

Item

2019

Quantity (in pounds)

Purchases of CCS staples produced in—
United States
China
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

Imports of CCS staples from—
China
All other countries1
Total imports3
1

Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported CCS staples at any time since January 1, 2017, please also complete and
return a U.S. importers' questionnaire in this proceeding.
2

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)
II-2.

Page 7

Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of CCS
staples from different sources have changed since January 1, 2017.

Source of
purchases

Did not
purchase Decreased Increased Constant Fluctuated

Explanation for trend

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

Country knowledge.--Please indicate the countries of origin with which your firm has
experience or information in the CCS staples market.
United States

II-4.

China

Other countries

Other countries (specify)

Supplier identification.--Please list your firm’s FIVE largest suppliers for CCS staples since
January 1, 2017. Also, provide the share of the quantity of your firm’s total purchases of CCS
staples that each of these suppliers accounted for in 2019.

No.

Supplier’s name

City and state

Share of quantity of
2019 purchases

1

%

2

%

3

%

4

%

5

%

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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 CCS staples (check
all that apply)?
Retailer

Contractor/
builder

Other end
user

Distributor

Other

Describe other

If your firm is a distributor of CCS staples, 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 CCS staples?
No

III-3.

Yes

If yes, please describe.

Types of customers.--What are the major types of consumers to which your firm sells CCS
staples?

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If your firm is an end user of CCS staples, please answer questions III-4 and III-5.
III-4.

End uses.--List the top 3 products your firm makes using CCS staples and estimate the percent of
your total production cost that is accounted for by CCS staples and by other inputs (such as
labor, energy, and other raw materials).
Share of total cost in each of the product(s) your
firm produces accounted for by
Product(s) your firm
produces

III-5.

CCS staples

Total
(should
sum to
100.0%
across)

Other inputs
% +

%

=

0.0 %

% +

%

=

0.0 %

% +

%

=

0.0 %

Demand for end-use products.-(a)

Has the demand for your firm’s final products incorporating CCS staples changed since
January 1, 2017?
Increased

(b)

No change

Decreased

Fluctuated

Has this had any effect on your firm’s demand for CCS staples?
No

Yes

Explain

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)
III-6.

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Substitutes.--Can other products be substituted for CCS staples?
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 CCS staples?
No Yes

Explanation

1.
2.
3.
III-7.

Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for CCS staples has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.

Overall
increase

Market

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Within the United States
Outside the United States
III-8.

Country preferences.--Do you or your customers ever specifically order CCS staples 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 - CCS Staples (Final)
III-9.

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Importance of purchasing domestic product.--Please fill out the table below, estimating the
percentage of your firm’s total 2019 purchases of CCS staples that required CCS staples
produced in the United States.
Estimated percentage of
your firm’s total 2019
purchases of CCS staples

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%)

%
%
%
%
0.0 %

III-10. Conditions of competition.-(a)

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

Check all that apply.

Please describe.

No

Skip to question III-11.

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 CCS
staples since January 1, 2017?
No

Yes

If yes, describe.

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III-11. Decisions based on producer and country-of-origin.--How often does your firm, and if known,
do your customers, make purchasing decisions involving CCS staples based on their producer or
country of origin?
Item

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-12. Availability of supply.--Has the availability of CCS staples in the U.S. market changed since
January 1, 2017?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
U.S.-produced product
Imports from China
Imports from other
countries
III-13. Supply constraints.--Has any firm refused, declined, or been unable to supply your firm with CCS
staples since January 1, 2017 (examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, delivering less
than the quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

III-14. Availability of specific product types.--Are certain grades/types/sizes of CCS staples only
available from certain country sources?
No

Yes

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

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III-15. Purchasing frequency.-(a)

How frequently does your firm make purchases of CCS staples (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Has this purchasing frequency changed since January 1, 2017?
No

Yes

If yes, please describe.

III-16. Raw material prices.—
(a)

Is your firm familiar with the prices for raw materials used in the production of CCS
staples?

No

(b)

Has information on raw material prices affected your firm’s negotiations or contracts to
purchase CCS staples since January 1, 2017?

No

(c)

Yes –
please answer (b)

Yes –
please answer (c) Explain

Have your contract purchases of CCS staples been indexed to raw material prices since
January 1, 2017?

No

Explain, noting to what percentage of your purchases this applies and
any lag time between index change and price change associated with
Yes such contracts

III-17. Number of suppliers contacted.--How many suppliers does your firm generally contact before
making a purchase? Between
and
firms

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III-18. Supplier negotiations.--Do your firm’s purchases of CCS staples 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-19. Change in suppliers.--Has your firm changed suppliers since January 1, 2017?

No

Yes

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

III-20. New suppliers.--Are you aware of any new suppliers, either foreign or domestic, that have
entered the market since January 1, 2017?
No

Yes

If yes, please identify the firms.

III-21. Supplier qualification.--Do you require your suppliers to be or to become certified or qualified
to sell CCS staples 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

III-22. Failure to certify.--Since January 1, 2017, have any domestic or foreign producers failed in their
attempts to certify or qualify their CCS staples 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.

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III-23. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase CCS staples (examples include availability,
extension of credit, contracts, price, quality, range of supplier’s product line, traditional supplier,
etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
III-24. Purchasing factors.--Please rate the importance of the following factors in your firm’s
purchasing decisions for CCS staples.

Factor
Availability
Delivery terms
Delivery time
Discounts offered
Minimum quantity requirements
Packaging
Payment terms
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs

Very
important

Somewhat
important

Not
important

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III-25. Quality characteristics.--What characteristics does your firm consider when determining the
quality of CCS staples?

III-26. Minimum quality.--How often do CCS staples 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
Other:
III-27. Frequency of decisions based on price.--How often does your firm purchase the CCS staples
that are offered at the lowest price?
Always

Usually

Sometimes

Rarely or never

III-28. 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 CCS staples market since
January 1, 2017.
Firm(s)

Describe how the firm(s) exhibited price leadership

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III-29. Purchasing subject imports rather than domestic products.—
(a)

Since January 2017, did your firm import and/or purchase imports of CCS staples from
China instead of purchasing U.S.-produced CCS staples?
Yes
No
Source
(also respond to parts (b) and (c))
(If “No”, skip to next question)
China

(b)

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

Yes

No

China
(c)

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

Source

China

Yes

If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2017
(in pounds)

No

If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product

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III-30. U.S. producers and import competition.—
(a)

Since January 1, 2017, in connection with a sale or offer to sell CCS staples to your firm,
did U.S. producers reduce their prices of domestically produced CCS staples in order to
compete with lower-priced imports of CCS staples from the subject countries?
Source

Yes (also respond to
question part (b))

No (If “No”, skip to next
question)

Don’t know

China
(b)

If your firm responded “yes”, 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
China

Estimated
reduction in U.S.
prices
(percent)
%

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

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III-31. Impact of Section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
Section 301 have an impact on the CCS staples market in the United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced CCS staples
Supply of CCS staples
imported from China
Supply of CCS staples
imported from other
countries
Prices for CCS staples
Overall U.S. demand
for CCS staples
Raw material costs for
CCS staples

No

Overall
No
Overall
increase change decrease

Don’t know

Fluctuate Explain, noting how the imposition
with no of tariffs under Section 301 affected
clear
each factor of the CCS staples market
trend
in the United States.

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PART IV.—PRODUCT COMPARISONS
IV-1.

Interchangeability.—Are the CCS staples produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

China

Other countries

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

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)
IV-2.

Page 21

Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CCS staples 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

Other countries

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

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U.S. Purchasers’ Questionnaire - CCS Staples (Final)
IV-3.

Page 22

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

Superior

Inferior

Comparable

Product from
United States
compared to
product from
other countries

Superior

Inferior

Comparable

Factor

Superior

Product from
United States
compared to product
from
China

Availability
Delivery terms
Delivery time
Discounts offered
Minimum quantity
requirements
Packaging
Payment terms
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.

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PART V.—ADDITIONAL INFORMATION
V-1.

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

V-2.

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.

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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/701731/2020/certain_collated_steel_staples_china/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: CCS

• E-mail.—E-mail the MS Word questionnaire to craig.thomsen@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 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.