20-2-4186 U.S. importers' questionnaire

OMB No. 3117-0016/USITC No. 20-2-4186; Expiration Date : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
CORROSION INHIBITORS FROM CHINA
This questionnaire must be received by the Commission by February 19, 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 antidumping and countervailing duty investigations concerning corrosion inhibitors from China (inv.
Nos. 701-TA-638 and 731-TA-1473 (Preliminary)). The information requested in the questionnaire is requested under
the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm imported corrosion inhibitors (as defined on next page) from any country 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: CORR)
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

Signature

Title of Authorized Official

Phone

Date

Email address

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background. --This proceeding was instituted in response to petitions filed on February 5, 2020, by
Wincom Incorporated, Blue Ash, 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 and/or dumping. Questionnaires
and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/corrosion_inhibitors_china/preliminary.htm.
Corrosion inhibitors covered by these investigations is tolyltriazole (“TTA”) and benzotriazole (“BTA”).
This includes tolyltriazole and benzotriazole of all grades and forms, including their sodium salt forms.
Tolyltriazole is technically known as Tolyltriazole IUPAC 4,5 methyl benzotriazole. It can also be
identified as methyl benzotriazole, tolutriazole, TTA, and TTZ.
Benzotriazole is technically known as IUPAC 1,2,3-Benzotriazole. It can also be identified as 1,2,3Benzotriazole, 1,2-Aminozophenylene, 1H-Benzotriazole, and BTA.
All forms of tolyltriazole and benzotriazole, including but not limited to flakes, granules, pellets, prills,
needles, powder, or liquids, are included within the scope of these petitions.
The scope includes tolyltriazole/sodium tolyltriazole and benzotriazole/sodium benzotriazole that are
combined or mixed with other products. For such combined products, only the tolyltriazole/sodium
tolyltriazole and benzotriazole/sodium benzotriazole component is covered by the scope of these
investigations. Tolyltriazole and sodium tolyltriazole that have been combined with other products is
included within the scope, regardless of whether the combining occurs in third countries.
Tolyltriazole, sodium tolyltriazole, benzotriazole and sodium benzotriazole that is otherwise subject to
these investigations is not excluded when commingled with tolyltriazole, sodium tolyltriazole,
benzotriazole, or sodium benzotriazole from sources not subject to these investigations. Only the
subject merchandise component of such commingled products is covered by the scope of these
investigations.
Tolyltriazole has the Chemical Abstracts Service (“CAS”) registry number 299385-43-1. Tolyltriazole is
classified under Harmonized Tariff Schedule of the United States (“HTSUS”) subheading 2933.99.82.20.
Sodium Tolyltriazole has the CAS registry number 64665-57-2 and is classified under HTSUS
2933.99.82.90.
Benzotriazole has the CAS registry number #95-14-7 and is classified under HTSUS 2933.99.82.10.
Sodium Benzotriazole has the CAS registry number 15217-42-2. Sodium Benzotriazole is classified under
HTSUS 2933.99.82.90.
Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs
purposes, the written description of the scope of these investigations is dispositive.

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Page 3

Corrosion inhibitors are currently imported under statistical reporting numbers 2933.99.8210 of the
Harmonized Tariff Schedule of the United States (HTSUS). They may also be imported under HTSUS
statistical reporting numbers 2933.99.8220 and 2933.99.8290. In their solid form, tolyltriazole and
benzotriazole are imported under HTS numbers 2933.99.8210 and 2933.99.8220, respectively. The
liquid forms of tolyltriazole and benzotriazole are imported under the “other” HTS category, i.e. HTS
2933.99.8290. The HTSUS provisions are for convenience and customs purposes; the written description
of the scope is dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing corrosion inhibitors (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from
Lawrence Jones (202-205-3358, lawrence.jones@usitc.gov).

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 4

D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
I-1.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
I-2a.

Page 5

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm involved in the importation of corrosion inhibitors,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

I-2b.

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

I-2c.

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-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, relating to the ultimate parent/owner.

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing corrosion inhibitors from China into the United States or
that are engaged in exporting corrosion inhibitors from China into the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of corrosion inhibitors?
No

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on
corrosion inhibitors. More than one answer may be applicable.
Importer of record

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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

Firm name

Address

Contact person
and phone
number

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
I-8.

Page 7

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters corrosion inhibitors
into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also
indicate whether your firm imports corrosion inhibitors under the TIB (temporary importation
under bond) program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond
I-9.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes

If yes, Yes–Please specify.

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, Lawrence.jones@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of corrosion inhibitors since January 1, 2017.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-3a.

Page 9

Arranged imports.--Has your firm imported or arranged for the importation of corrosion
inhibitors for delivery after December 31, 2019?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes
If yes, fill out the table below.

Period
Source

Jan-Mar 2020

Apr-Jun 2020

Jul-Sept 2020

Oct-Dec 2020

Quantity (in pounds, dry weight)
China
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported corrosion
inhibitors from any source between February 1, 2019 and January 30, 2020? (i.e., the eleven
months in 2019 and first month in 2020 combined)
No

Yes
If yes, report the quantity of such import below by source.

Quantity (in pounds, dry weight)
Source

February 2019 through January 2020

China
All other sources
II-4a.

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

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-4b.

Page 10

Conversion operations.-- Since January 1, 2017, has your firm further processed or refined or
purified corrosion inhibitors or converted solid corrosion inhibitors into liquid corrosion
inhibitors?

No

Yes

If yes--Please describe the nature and extent of the following items in
relation to your firm’s refining/purifying/conversion operations in the
United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type, and
source of parts
Costs and activities

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Page 11

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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 firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“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. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-5a.

Page 12

U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of corrosion inhibitors imported from China by your firm during the specified periods.

China
Quantity (in pounds, dry weight), value (in dollars)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity)
(A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

Please identify the foreign producers, if known:
.
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
2

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II-5a.

Page 13

U.S. imports from China.–Continued

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

2017

2018

A + B – D – F – H – J -L = should equal zero ("0") or
provide an explanation.1

2019

0

0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-5b.

Channels of distribution: China.--Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of imports from China by
channel of distribution during the specified periods.

China
Calendar years
Item

2017

2018

2019

Quantity (in pounds, dry weight)
Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To processers (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N + O – D - F - H = zero ("0"), if not revise.

2017

2018
0

2019
0

0

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-5c.

Page 14

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

CHINA
Quantity (in pounds, dry weight), value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
Tolyltriazole / sodium
tolytriazole:
Quantity (P)
Value (Q)
Benzotriazole / sodium
benzotriazole:
Quantity (R)
Value (S)
RECONCILIATION OF US SHIPMENTS BY TYPE--Please ensure that the quantities and value reported for U.S.
shipments by type (i.e., lines P through S) in each time period equal the quantities and values reported for U.S.
shipments (i.e., lines D through I) 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

2017

2018

2019

Quantity: P + R - D- F - H = zero ("0"),
if not revise.

0

0

0

Value: Q + S - E- G - I = zero ("0"), if
not revise.

0

0

0

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-6a.

Page 15

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of corrosion inhibitors imported from all other sources by your firm during the
specified periods.

All other sources
(list sources:

)
Quantity (in pounds, dry weight), value (in dollars)
Calendar years

Item

2017

2018

2019

Beginning-of-period inventories (quantity)
(A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

Please identify the foreign producers, if known:
.
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
2

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-6a.

Page 16

Imports from all other sources.–Continued

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

2017

2018

A + B – D – F – H – J -L = should equal zero ("0") or
provide an explanation.1

2019

0

0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-6b.

Channels of distribution: All other sources.-- Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.

All other sources
Calendar years
Item

2017

2018

2019

Quantity (in pounds, dry weight)
Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To processers (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N + O - D -F - H= zero ("0"), if not revise.

2017

2018
0

2019
0

0

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-6c.

Page 17

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

ALL OTHER SOURCES
Quantity (in pounds, dry weight); value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
Tolyltriazole / sodium
tolytriazole:
Quantity (P)
Value (Q)
Benzotriazole / sodium
benzotriazole:
Quantity (R)
Value (S)
RECONCILIATION OF US SHIPMENTS BY TYPE--Please ensure that the quantities and value reported for U.S.
shipments by type (i.e., lines P through S) in each time period equal the quantities and values reported for U.S.
shipments (i.e., lines D through I) 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

2017

2018

2019

Quantity: P + R - D- F - H = zero ("0"),
if not revise.

0

0

0

Value: Q + S - E- G - I = zero ("0"), if
not revise.

0

0

0

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 18

II-7.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non-market formula.

II-8.

Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative response box was not provided, 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.

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Page 19

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, amelia.preece@usitc.gov).
III-1.

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

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products your firm imported
from China:
Product 1.—Sodium Tolyltriazole in totes of 2400 to 2600 pounds net weight
Product 2.-- Sodium Tolyltriazole in drums of 450 to 550 pounds net weight
Product 3.—Tolyltriazolein supersacks 1000 to 1200 pounds net weight

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 2017-December 2019, did your firm import from China and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question III-3.

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

China

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

Period of shipment
2017:
January-March
April-June
July-September
OctoberDecember
2018:
January-March
April-June
July-September
OctoberDecember
2019:
January-March
April-June
July-September
OctoberDecember

(Quantity in pounds contained weigh, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part III.
1

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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III-2b.

Page 21

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

√ if Yes

In actual dollars (not $1,000) and pounds?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in part II in each year?
III-2c.

Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.

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U.S. Importers’ Questionnaire – Corrosion Inhibitors (Preliminary)
III-3.

Price setting.--How does your firm determine the prices that it charges for sales of corrosion
inhibitors (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction

III-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported corrosion inhibitors from China
usually quoted (check one)?
Delivered

III-6.

Set
price
lists

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

Quantity
discounts

III-5.

Page 22

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of corrosion inhibitors
imported from China in 2019 was on a (1) short-term contract basis, (2) annual contract basis,
(3) long-term contract basis, and (4) spot sales basis?

Item
Share of 2019
sales

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

Short-term
contracts
(multiple
deliveries for
less than 12
months)
%

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

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III-7.

Page 23

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
corrosion inhibitors imported from China (or check “not applicable” if your firm does not sell on
a short-term, annual and/or long-term contract basis).
Short-term contracts
(multiple deliveries
for less than 12
months)

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

Annual contracts
(multiple
deliveries for 12
months)

Long-term contracts
(multiple deliveries
for more than 12
months)

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

III-8.

.

Lead times.--What is your firm’s share of sales of corrosion inhibitors imported from China 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 corrosion inhibitors?

Source

Lead time
(Average number
Share of 2019 sales
of days)

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

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III-9.

Page 24

Shipping information.—
(a)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(b)

When your firm sells corrosion inhibitors imported from China, from where is it
shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of corrosion inhibitors
imported from China that are delivered the following distances from your firm’s U.S.
point of shipment.
Distance from your firm’s U.S. point of shipment

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold corrosion
inhibitors imported from subject countries since January 1, 2017 (check all that apply)?
Geographic area

China

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
III-11. Inland transportation costs.—What is the approximate percentage of the cost of corrosion
inhibitors imported from China that is accounted for by U.S. inland transportation costs?
percent.

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III-12. End uses.--List the end uses of the corrosion inhibitors that your firm imports. For each end-use
product, what percentage of the total cost is accounted for by corrosion inhibitors and other
inputs?
Share of total cost of end-use product
accounted for by
End-use product

corrosion inhibitors

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-13. Substitutes.--Can other products be substituted for corrosion inhibitors?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for corrosion inhibitors?
No Yes

Explanation

1.
2.
3.
III-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for corrosion inhibitors has changed since January 1, 2017. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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Page 26

III-15. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of corrosion inhibitors since January 1, 2017?
No

Yes

If yes, please describe.

III-16. Conditions of competition.—
(a) Is the corrosion inhibitors market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to corrosion inhibitors?
Check all that apply.

Please describe.

No

Skip to question III-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
corrosion inhibitors since January 1, 2017?
No

Yes

If yes, describe.

III-17. Supply constraints.--Has your firm refused, declined, or been unable to supply corrosion
inhibitors 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.

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Page 27

III-18. Raw materials.--How have corrosion inhibitors raw material prices changed since January 1,
2017?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for
corrosion inhibitors.

III-19. Interchangeability.--Is corrosion inhibitors 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 corrosion inhibitors that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

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III-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between corrosion inhibitors
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair

Country-pair

China

Other countries

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

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Page 29

III-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for corrosion inhibitors since January 1, 2017. Indicate the share of the quantity of
your firm’s total shipments of corrosion inhibitors that each of these customers accounted for in
2019.

Customer’s name

Contact person

Email

Telephone

City

State

Share
of
2019
sales
(%)

1
2
3
4
5
6
7
8
9
10
III-22. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, 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.

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Page 30

PART IV.--ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, lawrence.jones@usitc.gov).
IV-1.

Comparability of types of corrosion inhibitors.--For each of the following indicate whether
listed products are: fully comparable or the same, i.e., have no differentiation between them;
mostly comparable or similar; somewhat comparable or similar; never or not-at-all comparable
or similar; or no familiarity with products.
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 End 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 tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole
(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair
In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

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

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IV-1.

Page 31

Comparability of types of Corrosion inhibitors. --Continued
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.
(c) Manufacturing facilities, production processes, and production employees.--Whether
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 tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

(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 tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

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

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IV-1.

Page 32

Comparability of types of Corrosion inhibitors.--Continued
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.
(e) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities 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 product perceptions:

In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair
In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

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

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Page 33

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The U.S. International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

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

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Page 34

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/corrosion_inhibitors_china/preliminary.htm.
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CORR

• E-mail.—E-mail the MS Word questionnaire to Lawrence.jones@usitc.gov; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.