20-2-4202 U.S. importers' questionnaire

OMB No. 3117-0016/USITC No. 20-2-4202; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
ULTRA-HIGH MOLECULAR WEIGHT POLYETHYLENE FROM KOREA
This questionnaire must be received by the Commission by March 17, 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 investigation concerning ultra-high molecular height polyethylene (“UHMWPE”) from
Korea (Inv. No. 731-TA-1474 (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 UHMWPE (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: POLY)

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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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed effective March 4, 2020, by
Celanese Corporation, Irving, Texas. Antidumping duties may be assessed on the subject imports as a
result of this proceeding 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 dumping. Questionnaires and other information pertinent to this proceeding are
available at
https://www.usitc.gov/investigations/701731/2020/ultrahigh_molecular_plolyethelene/preliminary.ht
m
Ultra-High Molecular Weight Polyethylene (UHMWPE): The product covered by this investigation is
ultra-high molecular weight polyethylene (UHMWPE). UHMWPE is a linear polyethylene, in granular or
powder form. It is defined by its melt mass-flow rate of <0.1 g/10 min, measured at 190 °C and 21.6 kg
load, based on the methods and calculations set forth in the International Organization for
Standardization (ISO) standards 21304-1 and 21304-2. UHMWPE generally has a Chemical Abstract
Service (“CAS”) registration number of 9002-88-4.
The scope includes all UHMWPE in granular or powder forms meeting the above specifications
regardless of additives introduced in the manufacturing process. UHMWPE blended with other products
is included in the scope of this investigation where UHMWPE is the predominant material within the
blend.
Excluded from the scope of the investigation is medical-grade UHMWPE. Medical-grade
UHMWPE has a minimum viscosity of 2000 ml/g at a concentration of 0.02% at 135°C (275 °F) in
decahydronaphthalene and an elongational stress of 0.2 MPa or greater. Medical-grade UHMWPE is
further defined by its ash and trace element content, which shall not exceed the following maximum
quantities as set forth in ISO 5834-1: ash (125 mg/kg), titanium (40 mg/kg), calcium (5 mg/kg), chlorine
(30 mg/kg), and aluminum (20 mg/kg). ISO 5834-1 further defines medical-grade UHMWPE by its
particulate matter content, which requires that there shall be no more than three particles of
contaminant per 300 ± 20 g tested. Each of the above criteria is calculated based on the standards and
methods used in ISO 5834-1.
UHMWPE is currently imported under statistical reporting numbers 3901.10.10.00 and 3901.20.10.00 of
the Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions are for convenience
and customs purposes; the written description of the scope is dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing UHMWPE (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.

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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 Andres
Andrade (202-205-2078, Andres.Andrade@usitc.gov).
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.

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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-2a.

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 UHMWPE, 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

Yes--List the following information, relating to the ultimate parent/owner.

Country

Extent of
ownership
(percent)

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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
I-4.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing UHMWPE from Korea into the United States or that are
engaged in exporting UHMWPE from Korea to the United States?
No

Yes--List the following information.

Firm name

I-5.

Country

Affiliation

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

Yes--List the following information.

Firm name

I-6.

Page 5

Country

Affiliation

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

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
I-7.

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

Firm name

I-8.

Page 6

Contact person
and phone
number

Address

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters UHMWPE into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports UHMWPE 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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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Andres Andrade (202-2052078, andres.andrade@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 UHMWPE 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 - UHMWPE (Preliminary)
II-3a.

Page 8

Arranged imports.--Has your firm imported or arranged for the importation of UHMWPE 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)
Korea
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported UHMWPE
from any source between March 1, 2019 and February 29, 2020? (i.e., the last ten months in
2019 and first two months in 2020 combined)
No

Yes

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

Quantity (in pounds)
Source

March 2019 through February 2020

Korea
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces UHMWPE 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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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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II-5a.

Page 10

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

Korea
Quantity (in pounds), value (in $1,000)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity)
(A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:2
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related firms:3
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Please identify the foreign producers, if known:
.
Indicate the share of your firm U.S. shipments that were sold compounded or blended:
percent.
3
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.
4
Identify your firm’s principal export markets:
.
1
2

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II-5a.

Page 11

U.S. imports from Korea.–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

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
1

II-5b.

Channels of distribution: Korea.--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 Korea by
channel of distribution during the specified periods.

Korea
Calendar years
Item

2017

2018

2019

Quantity (in pounds)
Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To blenders/compounders (O)
1

Please identify your firms top blender/compounder customers:

.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through 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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II-5c.

Page 12

U.S. imports by application: Korea.—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 Korea by application in calendar year 2019.

Korea
Quantity (in pounds)
Calendar year
Item

2019

U.S. shipments by application:
Membranes (P)
Filtration (Q)
Batteries (R)
Fibers (S)
Additives (T)
Others1 (U)
1

Please identify these products:

.

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities reported for shipments by application (i.e.,
lines P through U) in calendar year 2019 equal the quantity reported for U.S. shipments (i.e., line D, F, H) in
calendar year 2019. 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 year
Reconciliation
P + Q + R + S + T + U – D – F – H = zero ("0"), if not revise.

2019
0

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II-6a.

Page 13

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

(list sources:

All other sources
)
Quantity (in pounds), value (in $1,000)
Calendar years

Item

2017

2018

2019

Beginning-of-period inventories (quantity)
(A)
Imports:1 2
Quantity (B)
Value (C)

0

0

0

0

0

0

U.S. shipments:
Commercial shipments:
Quantity (D)
3

Value (E)
Internal consumption:4
Quantity (F)
Value4 (G)
Transfers to related firms:4
Quantity (H)
Value4 (I)
Export shipments:5
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Please identify the foreign producers, if known:
.
Imports reported on lines B and C will populate here once reported in question II-6d below.
3
Indicate the share of your firm U.S. shipments that were sold compounded or blended:
percent.
4
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.
5
Identify your firm’s principal export markets:
.
1
2

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II-6a.

Page 14

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

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
1

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)
Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To blenders/compounders (O)
RECONCILIATION OF CHANNELS.–Please ensure that the quantities reported for channels of distribution
(i.e., lines M through 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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II-6c.

Page 15

U.S. imports by application: 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 application during the specified periods.
Quantity (in pounds)
Calendar year
Item

2019

U.S. shipments by application:
Membranes (P)
Filtration (Q)
Batteries (R)
Fibers (S)
Additives (T)
Others1 (U)
1

Please identify these products:

.

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities reported for shipments by application (i.e.,
lines P through U) in calendar year 2019 equal the quantity reported for U.S. shipments (i.e., line D, F, H) in
calendar year 2019. 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 year
Reconciliation
P + Q + R + S + T + U – D – F – H = zero ("0"), if not revise.

2019
0

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II-6d.

Page 16

U.S. imports from all other sources by source.—Report your firm’s U.S. imports from all other
sources by source during the specified time periods.
Quantity (in pounds), value (in $1,000)
Calendar years
Country

2017

2018

2019

U.S. imports:
Brazil:
Quantity
Value
China:
Quantity
Value
Japan:
Quantity
Value
Netherlands:
Quantity
Value
All other sources:
Quantity
Value
Total imports from
nonsubject sources:
Quantity (V)
Value

0

0

0

0

0

0

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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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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Kyle Westmoreland (202205-2184, kyle.westmoreland@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 Korea:
Product 1.--UHMWPE, with an average molecular weight/volume ranging from 6.7 to 7
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with a net weight of 25kg.
Product 2.--UHMWPE, with an average molecular weight/volume ranging from 6.7 to 7
106g/mol based on the producer’s advertised testing methodology; in bulk
packaging with a net pallet weight of 130,000 lbs (59 MT) to 140,000 lbs (63.5 MT).
Product 3.--UHMWPE, with an average molecular weight/volume ranging from 8.7 to 9
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with net weight greater than 453kg but less than 500 kg.
Product 4.--UHMWPE, with an average molecular weight/volume ranging from 8.7 to 9
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with net weight ranging from 500 kg to 550 KG.

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 Korea 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 Korea
and sold by your firm.
Report data in pounds and dollars (not 1,000s).

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

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

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

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
III-2b.

Page 20

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.

Business Proprietary
U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
III-3.

Price setting.--How does your firm determine the prices that it charges for sales of UHMWPE
(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 UHMWPE from Korea 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 21

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of UHMWPE imported
from Korea in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) longterm 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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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
III-7.

Page 22

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
UHMWPE imported from Korea (or check “not applicable” if your firm does not sell on a shortterm, 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 UHMWPE imported from Korea 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 UHMWPE?

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 %

Business Proprietary
U.S. Importers’ Questionnaire - UHMWPE (Preliminary)
III-9.

Page 23

Shipping information.—
(a)

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

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of UHMWPE imported from
Korea 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 UHMWPE
imported from Korea since January 1, 2017 (check all that apply)?
Geographic area

Korea

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 UHMWPE
imported from Korea that is accounted for by U.S. inland transportation costs?
percent.

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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 24

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

UHMWPE

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-13. Substitutes.--Can other products be substituted for UHMWPE?
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 UHMWPE?
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 UHMWPE 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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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 25

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

Yes

If yes, please describe.

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

Please describe.

No

Skip to question III-17.

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

Yes

If yes, describe.

III-17. Supply constraints.--Has your firm refused, declined, or been unable to supply UHMWPE 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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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 26

III-18. Raw materials.--How have UHMWPE 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
UHMWPE.

III-19. Interchangeability.--Is UHMWPE 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

Korea

Other countries

United States
Korea
For any country-pair producing UHMWPE that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 27

III-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between UHMWPE 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

Korea

Other countries

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

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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 28

III-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for UHMWPE since January 1, 2017. Indicate the share of the quantity of your firm’s
total shipments of UHMWPE 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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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 29

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 setup 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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U.S. Importers’ Questionnaire - UHMWPE (Preliminary)

Page 30

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/ultrahigh_molecular_plolyethelene
/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: POLY

• E-mail.—E-mail the MS Word questionnaire to Andres.Andrade@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.