20-2-4222 U.S. importers' questionnaire

OMB No. 3117-0016/USITC No. 20-2-4222; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
NON-REFILLABLE STEEL CYLINDERS FROM CHINA
This questionnaire must be received by the Commission by April 10, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning non-refillable steel cylinders from
China (Inv. Nos. 701-TA-644 and 731-TA-1494 (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 non-refillable steel cylinders (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: NRSC)
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 on March 27, 2020, by
Worthington Industries, Columbus, Ohio. Countervailing and 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 dumping. Questionnaires and
other information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2020/non_refillable_steel_cylinders_china/preliminary.htm.
Non-refillable steel cylinders covered by these investigations are certain non-refillable steel cylinders
meeting the requirements of, or produced to meet the requirements of, U.S. Department of
Transportation (“USDOT”) Specifications 39, TransportCanada Specification 39M, or United Nations
pressure receptacle standard ISO 11118 and otherwise meeting the description provided below
(“nonrefillable steel cylinders”). The subject non-refillable steel cylinders are portable and range from
300-cubic inch (4.9 liter) water capacity to 1,526-cubic inch (25 liter) water capacity. Subject non
refillable steel cylinders may be imported with or without a valve and/or pressure release device and
may be filled or unfilled at the time of importation.
Specifically excluded are seamless non-refillable steel cylinders.
Also excluded from the scope of these petitions are non-refillable steel cylinders filled at the time of
importation whose content is subject to another antidumping and/or countervailing duty order. At the
time of filing this petition, there are existing antidumping duty orders on Hydrofluorocarbon Blends
from the People’s Republic of China and 1,1,1,2-Tetrafluoroethane (R-134A) from the People’s Republic
of China. See Hydrofluorocarbon Blends From the People’s Republic of China: Antidumping Duty Order,
81 Fed. Reg. 55,436 (Dep’t Commerce Aug. 19, 2016); 1,1,1,2 Tetrafluoroethane (R-134a) from the
People’s Republic of China: Antidumping Duty Order, 82 Fed. Reg. 18,422 (Dep’t Commerce Apr. 19,
2017). In the case of non-refillable steel cylinders entering the United States filled with merchandise
covered by the scope of these orders or future antidumping and/or countervailing duty orders covering
the gas or material content of the nonrefillable steel cylinders, such other orders control. In the case of
non-refillable steel cylinders entering the United States filled with merchandise not covered by the
scope of any other antidumping and/or countervailing duty order, the scope of this petition controls.
Non-refillable steel cylinders are currently imported under statistical reporting numbers 7311.00.0060
and 7311.00.0090 of the Harmonized Tariff Schedule of the United States (HTSUS). They may also be
imported under HTSUS statistical reporting number 7310.29.0025. 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 non-refillable steel cylinders (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

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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 Kristina
Lara (202-205-3386, kristina.lara@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.

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U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
I-1.

Page 4

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.
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 non-refillable steel
cylinders, 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):

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U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
I-3.

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

Firm name

I-4.

Page 5

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 non-refillable steel cylinders from China into the United
States or that are engaged in exporting non-refillable steel cylinders from China to the United
States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of non-refillable steel cylinders?
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 nonrefillable steel cylinders. 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 non-refillable steel cylinders 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 - Non-Refillable Steel Cylinders (Preliminary)
I-8.

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FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters non-refillable steel
cylinders into, or withdraws such merchandise from, foreign trade zones or bonded warehouses.
Also indicate whether your firm imports non-refillable steel cylinders 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 non-refillable steel cylinders 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 Kristina Lara (202-205-3386,
kristina.lara@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 non-refillable steel cylinders 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 - Non-Refillable Steel Cylinders (Preliminary)
II-3a.

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Arranged imports.--Has your firm imported or arranged for the importation of non-refillable
steel cylinders 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.
•

Do not report any arranged imports of non-refillable steel cylinders that will be filled
with either any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2tetrafluoroethane (R-134A) at the time of importation to the U.S.

No

Yes

If yes, fill out the table below.

Period
Source

Jan-Mar 2020

Apr-Jun 2020

Jul-Sept 2020

Quantity (in units)
China, unfilled
China, filled
All other sources, unfilled
All other sources, filled

Oct-Dec 2020

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II-3b.

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Imports in the 12 month period preceding the petition.--Has your firm imported non-refillable
steel cylinders 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)
•

Do not report any arranged imports of non-refillable steel cylinders that will be filled
with either any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2tetrafluoroethane (R-134A) at the time of importation to the U.S.

No

Yes

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

Quantity (in units)
Source

March 2019 through February 2020

China, unfilled
China, filled
All other sources, unfilled
All other sources, filled
II-4.

Reasons for importing if producer.--If your firm also produces non-refillable steel cylinders 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. For the purposes of this questionnaire,
commercial U.S. shipments should include (a) sales to distributors (firms that resell the cylinder
in the same format it was purchased/imported, i.e., do no not include sales to gas distributors
that fill unfilled cylinders as distributors), (b) sales to retailers, and (c) commercial sales to end
users (which include gas distributors or “fillers”) ; but should not include retail level sales made
to individual customers through your firm's own retail establishments.
“Internal consumption/ including for own retail sale”--Product consumed internally by your
firm, which includes merchandise that your firm transferred to your own firm’s retail
establishments for retail level sales. Such transactions are to be valued at fair market value and
not the total value of final downstream processed merchandise in the case of internal
consumption, nor the retail sale value in the case of your firm owning and operating its own
retail establishments.
“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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Please refer to the following guidance as you complete questions II-5a through II-8b:
Imported
Imported unfilled

Activities conducted in United
States
Re-sold unfilled
Filled with gas / liquid other
than HFC blends or R-134a in
the United States, then sold
Filled with an HFC blend under
AD/CVD order or R-134a (also
under order) in the United
States, then sold
Installed or included the cylinder
without gas into other larger
machinery

Imported filled, but not
with an HFC blend under
AD/CVD order or R-134a

Re-sold as is

Own firm uses the gas contained
within containers

Installed or included the
cylinder, including the contained
gas, into other larger machinery
Imported filled with an
HFC blend under AD/CVD
order or R-134a

Re-sold as is

Own firm uses the gas contained
within containers
Installed or included the cylinder
including the contained gas into
other larger machinery

Reporting in part II questions II-5a
through II-8b
Report imports under II-5a and II-7a,
and report usage as commercial sales
in II-5a and II-7a.
Report imports under II-5a and II-7a,
and report usage as commercial sales
in II-5a and II-7a, excluding the value
of the contained gas / liquid.
Report imports under II-5a and II-7a,
and report usage as internal
consumption in II-5a and II-7a,
excluding the value of the contained
gas / liquid.
Report imports under II-5a and II-7a,
and report as internal consumption in
II-5a and II-7a, excluding the value of
downstream machinery
Report imports under II-6a and II-8a
(excluding value of contained gas),
and report usage as commercial sales
in II-6a and II-8a (excluding value of
contained gas).
Report imports under II-6a and II-8a,
(excluding value contained gas) and
report usage as internal consumption
in II-6a and II-8a (excluding value
contained gas).
Report imports under II-6a and II-8a,
and report as internal consumption in
II-6a and II-8a, excluding the value of
downstream machinery and excluding
the value of the contained gas.
Do not report anywhere.

Do not report anywhere.
Do not report anywhere.

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II-5a. U.S. imports of unfilled cylinders from China.–Report your firm’s imports and your firm’s
shipments and inventories of unfilled, non-refillable, steel cylinders imported from China by
your firm during the specified periods.

China – Unfilled
Quantity (in units), value (in dollars)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity) (A)
U.S. imports:1 2
Unfilled cylinders:
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for own retail sale: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:
.
What percentage of your U.S. imports consisted of 9.5 inches in diameter cylinders?
%
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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U.S. imports from China - unfilled.–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
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

2017

2018
0

2019
0

0

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

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

China – Unfilled
Quantity (in units) and Value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
To distributors1 / retailers
Quantity (M)
Value (N)
To fillers / end users:
Quantity (O)
Value (P)
1
Firms that resell the cylinder in the same format it was purchased/import (i.e., do not include sales to gas distributors
that fill unfilled cylinders as distributors).

RECONCILIATION OF CHANNELS.--Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) 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 item

2017

2018

2019

Quantity: M + O – D – F – H = zero
("0"), if not revise.

0

0

0

Value: N + P – E – G – I = zero ("0"), if
not revise.

0

0

0

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II-6a.

•
•

Page 16

U.S. imports of filled cylinders from China.–Report your firm’s imports and your firm’s
shipments and inventories of filled, non-refillable, steel cylinders imported from China by your
firm during the specified periods.
Do not report any arranged imports of non-refillable steel cylinders that will be filled with either
any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2-tetrafluoroethane (R134A) at the time of importation to the U.S.
When reporting values of filled cylinders, only report the value of the cylinder itself, not the
contents it is filled with.

China – Filled1

Quantity (in units), value (in dollars)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity) (A)
U.S. imports:2 3 4
Filled cylinders:
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for own retail sale:5
Quantity (F)
Value5 (G)
Transfers to related firms:5
Quantity (H)
Value5 (I)
Export shipments:6
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Please identify all contents the cylinders are filled with:
.
Please identify the foreign producers, if known:
.
3
Report only the value of the cylinder itself, do not include the value of its filled contents. Please confirm that you only
(check=yes), and describe how your firm reported the value of the cylinder alone
reported the value of the cylinder alone:
(e.g., based on "specific invoice records", or based on firm "estimates of the cylinder’s share of total value", et cetera):
.
4
What percentage of your U.S. imports consisted of 9.5 inches in diameter cylinders?
%
5
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.
6
Identify your firm’s principal export markets:
.
1
2

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

2017

2018
0

2019
0

0

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

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-6b.

•
•

Page 18

Channels of distribution: China - filled.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
filled, non-refillable, steel cylinders from China by channel of distribution during the specified
periods.
Do not report any arranged imports of non-refillable steel cylinders that will be filled with either
any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2-tetrafluoroethane (R134A) at the time of importation to the U.S.
When reporting values of filled cylinders, only report the value of the cylinder itself, not the
contents it is filled with.

China – Filled
Quantity (in units) and Value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
To distributors / retailers
Quantity (M)
Value1 (N)
To end users:
Quantity (O)
Value1 (P)
1

Report only the value of the cylinder itself, do not include the value of its filled contents.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) 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 item

2017

2018

2019

Quantity: M + O – D – F – H = zero
("0"), if not revise.

0

0

0

Value: N + P – E – G – I = zero ("0"), if
not revise.

0

0

0

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-7a.

Page 19

U.S. imports of unfilled cylinders from all other sources.–Report your firm’s imports and your
firm’s shipments and inventories of unfilled, non-refillable, steel cylinders imported from all
other sources by your firm during the specified periods.

All other sources – unfilled
Quantity (in units), value (in dollars)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity) (A)
U.S. imports:1 2
Unfilled cylinders:
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for own retail sale: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:
.
What percentage of your U.S. imports consisted of 9.5 inches in diameter cylinders?
%
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

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-7a.

Page 20

U.S. imports from all other sources - unfilled.–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
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

2017

2018
0

2019
0

0

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

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-7b.

Page 21

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

All other sources – Unfilled
Quantity (in units) and Value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
To distributors1 / retailers
Quantity (M)
Value (N)
To fillers / end users:
Quantity (O)
Value (P)
1
Firms that resell the cylinder in the same format it was purchased/import (i.e., do not include sales to gas distributors
that fill unfilled cylinders as distributors).

RECONCILIATION OF CHANNELS.--Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) 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 item

2017

2018

2019

Quantity: M + O – D – F – H = zero
("0"), if not revise.

0

0

0

Value: N + P – E – G – I = zero ("0"), if
not revise.

0

0

0

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-8a.

•
•

Page 22

U.S. imports of filled cylinders from all other sources.–Report your firm’s imports and your
firm’s shipments and inventories of filled, non-refillable, steel cylinders imported from all other
sources by your firm during the specified periods.
Do not report any arranged imports of non-refillable steel cylinders that will be filled with either
any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2-tetrafluoroethane (R134A) at the time of importation to the U.S.
When reporting values of filled cylinders, only report the value of the cylinder itself, not the
contents it is filled with.

All other sources – Filled1
Quantity (in units), value (in dollars)

Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity) (A)
U.S. imports:2 3 4
Filled cylinders:
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for own retail sale:5
Quantity (F)
Value5 (G)
Transfers to related firms:5
Quantity (H)
Value5 (I)
Export shipments:6
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Please identify all contents the cylinders reported are filled with:
.
Please identify the foreign producers, if known:
.
3
Report only the value of the cylinder itself, do not include the value of its filled contents. Please confirm that you only
(check=yes), and describe how your firm reported the value of the cylinder alone
reported the value of the cylinder alone:
(e.g., based on "specific invoice records", or based on firm "estimates of the cylinder’s share of total value", et cetera):
.
4
What percentage of your U.S. imports consisted of 9.5 inches in diameter cylinders?
%
5
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.
6
Identify your firm’s principal export markets:
.
1
2

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
II-8a.

Page 23

U.S. imports from all other sources - filled.–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
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

2017

2018
0

2019
0

0

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

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)

Page 24

II-8b.

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

•

Do not report any arranged imports of non-refillable steel cylinders that will be filled with either
any hydrofluorocarbon blends under an existing AD/CVD order or 1,1,1,2-tetrafluoroethane (R134A) at the time of importation to the U.S.
When reporting values of filled cylinders, only report the value of the cylinder itself, not the
contents it is filled with.

•

All other sources – Filled
Quantity (in units) and Value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
To distributors / retailers
Quantity (M)
Value1 (N)
To end users:
Quantity (O)
Value1 (P)
1

Report only the value of the cylinder itself, do not include the value of its filled contents.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) 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 item

2017

2018

2019

Quantity: M + O – D – F – H = zero
("0"), if not revise.

0

0

0

Value: N + P – E – G – I = zero ("0"), if
not revise.

0

0

0

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)

Page 25

II-9.

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-10.

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.

Business Proprietary
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Page 26

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache
(lauren.gamache@usitc.gov, 202-205-3489).
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.-- Non-refillable steel cylinder, 9.5-inches in diameter, with 260 PSIG service pressure
rating, unfilled, meeting the requirements of U.S. Department of Transportation
specification 39.
Product 2.-- Non-refillable steel cylinder, 9.5-inches in diameter, with 400 PSIG service pressure
rating, unfilled, meeting the requirements of U.S. Department of Transportation
specification 39.

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.

Business Proprietary
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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 – Unfilled
Report data in units and actual 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 units, value in dollars)
Product 1
Quantity
Value

Product 2
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 IV.

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:

III-2b.

Price data checklist.--Please check that the pricing data in question III-2(a) has been correctly
reported.
Are the price data reported above:
In actual dollars (not $1,000) and units?
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?
Excludes sales of cylinders filled with gas/liquid

√ if Yes

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
III-2c.

Page 28

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.

PURCHASE COST DATA
III-3.

This question requests quarterly quantity and landed-duty paid value data for your firm’s
imports of the products defined above (p. 20) for internal consumption, repackaging, or use for
sales in your firm’s retail locations from China since January 1, 2017
During January 2017-December 2019, did your firm import any of the products listed on page 20
from China for internal consumption, repackaging, or use for sales in your firm’s retail locations?
Yes.--Please complete the following table(s) as appropriate.
No.--Skip to question III-4.

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Page 29

III-3a. Imports for internal use, repackaging, or retail sale.—Report below the import data1 for pricing
products2 imported from China and used by your own firm or sold at retail.
Please note that values should be landed, duty-paid (LDP) and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should be net
of all returns, discounts, allowances, and rebates).

China – Unfilled
Report data in units and actual dollars (not 1,000s).

Period of importation

(Quantity in units, value in dollars)
Product 1
Quantity
LDP Value

Product 2
Quantity

LDP Value
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
1 LDP value (i.e., landed duty-paid 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). See “Import values” definition in Part II (Trade and Related Information – Definitions).
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:

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U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)

Page 30

The following questions ask about the costs/benefits (not included in the LDP values reported above)
that factor into your firm’s decision to import non-refillable steel cylinders rather than purchase from
a U.S. producer or importer of non-refillable steel cylinders.
III-3b. Additional costs for your firm’s imports of non-refillable steel cylinders for your firm’s internal
use, repackaging, or retail sale.—
i.

Did your firm incur any additional costs by importing non-refillable steel cylinders rather
than purchasing from a U.S. producer or importer (e.g., logistical or supply chain
management costs, warehousing/inventory carrying costs, insurance or other risk
management fees, demurrage fees, indirect and overseas costs)?
No

Yes—Please answer parts ii, iii, and iv.

ii.

Please provide an estimate of the total additional cost incurred (as a percentage
compared to LDP value) when importing non-refillable steel cylinders rather than
purchasing from a U.S. producer or importer. (Report only the portion that is related to
your firm’s importing activities, either directly or indirectly, and not already included in
the LDP value. Do NOT include any costs that also would be incurred if your firm
purchased the product from a U.S. producer or importer.)
percent compared to
LDP value.

iii.

Please identify and explain the specific additional costs incurred by your firm and
estimate each cost (in percent) compared to the cost of importing. (Only report costs
and the portion of each cost that was related to your firm’s importing activities for nonrefillable steel cylinders, either directly or indirectly, and that are not already included in
the LDP value. Do NOT report costs that your firm would incur when purchasing nonrefillable steel cylinders from a U.S. producer or importer.)

Costs

iv.

Estimated
percentage
compared to LDP
value (percent)
%
%
%
%

Explanation

Briefly describe how your firm’s additional costs (beyond the purchase price) by
importing non-refillable steel cylinders directly compare with the additional costs your
firm incurs when purchasing from a U.S. producer or U.S. importer.

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
III-3c.

Page 31

Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import non-refillable steel cylinders? Check all that apply.

U.S. importers

U.S. producers

Neither U.S. importers
nor U.S. producers

III-3d. Benefits of importing non-refillable steel cylinders.
i.

Briefly identify the benefits of importing non-refillable steel cylinders instead of
purchasing non-refillable steel cylinders from a U.S. importer or from a U.S. producer.

ii.

Is it your firm’s experience that the non-refillable steel cylinders your firm imported
from China are priced lower than they would be if your firm purchased from a U.S.
importer or U.S. producer?
Imports are priced lower when

No

Yes (If yes to either, please
answer parts iii and iv.)

Not including the additional costs above
Including the additional costs above
iii.

Please estimate your firm’s savings by importing non-refillable steel cylinders instead of
purchasing from a U.S. producer or U.S. importer since January 1, 2017 (as a percent of
the purchase price from the U.S. importer or U.S. producer). For your estimate,
compare the price of purchasing from a U.S. importer or U.S. producer to the cost of
direct imports (including the additional costs described above in III-3b).

Factors

iv.

Estimated savings
(percent of purchase price from
U.S. importer/producer)

U.S. producer

%

U.S. importer

%

What methods or experience did you base the estimates in III-3diii (i.e. based on
previous transactions with U.S. producers and/or U.S. importers, market research, etc.)
Check all that apply.
Reported estimates in III-3diii based on
Previous company transactions
Market research
Other – Please explain

√ if Yes

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Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of these data, as Commission staff may contact your firm regarding questions. 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.
III-4.

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

III-5.

Annual
total
volume
discounts

If other, describe

No
discount
policy

Other

Describe

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

III-7.

Other

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

Quantity
discounts

III-6.

Contracts

Set
price
lists

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of non-refillable steel
cylinders 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

%

Business Proprietary
U.S. Importers’ Questionnaire - Non-Refillable Steel Cylinders (Preliminary)
III-8.

Page 33

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
non-refillable steel cylinders 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-9.

.

Lead times.--What is your firm’s share of sales of non-refillable steel cylinders 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 non-refillable steel cylinders?

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-10. Shipping information.—
(a)

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

(b)

When your firm sells non-refillable steel cylinders 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 non-refillable steel cylinders
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-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold nonrefillable steel cylinders 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-12. Inland transportation costs.—What is the approximate percentage of the cost of non-refillable
steel cylinders imported from China that is accounted for by U.S. inland transportation
costs?
percent.

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III-13. End uses.--List the end uses of the non-refillable steel cylinders that your firm imports. For each
end-use product, what percentage of the total cost is accounted for by non-refillable steel
cylinders and other inputs?
Share of total cost of end-use product
accounted for by
Non-refillable steel
cylinders

End-use product

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-14. Substitutes.--Can other products be substituted for non-refillable steel cylinders?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the price of this substitute
affected the price for non-refillable steel
cylinders?
No Yes

Explanation

1.
2.
3.
III-15. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for non-refillable steel cylinders has changed since January 1, 2017. Explain
any trends and describe the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within the United States
Outside the United States
III-16. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of non-refillable steel cylinders since January 1, 2017?
No

Yes

If yes, please describe.

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III-17. Conditions of competition.—
(a) Is the non-refillable steel cylinders market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to nonrefillable steel cylinders?
Check all that apply.

Please describe.

No

Skip to question III-18.

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
non-refillable steel cylinders since January 1, 2017?
No

Yes

If yes, describe.

III-18. Supply constraints.--Has your firm refused, declined, or been unable to supply non-refillable
steel cylinders since January 1, 2017 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No

Yes

If yes, please describe.

III-19. Raw materials.—
(a) How have non-refillable steel cylinders 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 nonrefillable steel cylinders.

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III-19. Raw materials.— Continued.
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for non-refillable steel cylinders?

Factor

Overall increase

No change

Overall decrease

Fluctuate with
no clear trend

Cost of raw materials after
section 232 tariffs imposed
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for non-refillable steel cylinders?

Factor
Prices for non-refillable
steel cylinders

Overall
Increase

No change

Fluctuate
Overall
with no
Decrease clear trend

Explanation

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III-20. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the non-refillable steel cylinders market in the United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced nonrefillable steel
cylinders
Supply of nonrefillable steel
cylinders imported
from China
Supply of nonrefillable steel
cylinders imported
from other countries
Prices for nonrefillable steel
cylinders
Overall U.S. demand
for non-refillable steel
cylinders
Raw material costs for
non-refillable steel
cylinders

No

Overall
No
Overall
increase change decrease

Don’t know

Explain, noting how the imposition
Fluctuate of tariffs under section 301 affected
with no
each factor of the non-refillable
clear
steel cylinders market in the United
trend
States.

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III-21. Interchangeability.--Is non-refillable steel cylinders 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 non-refillable steel cylinders that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude interchangeable
use:

III-22. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between non-refillable steel
cylinders 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 non-refillable steel cylinders, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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III-23. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for non-refillable steel cylinders since January 1, 2017. Indicate the share of the
quantity of your firm’s total shipments of non-refillable steel cylinders 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-24. 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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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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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://usitc.gov/investigations/701731/2020/non_refillable_steel_cylinders_china/prel
iminary.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: NRSC

• E-mail.—E-mail the MS Word questionnaire to kristina.lara@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.