The sales databases must also contain, for each reported transaction, specific information on the physical characteristics of the product being sold. Usually, the Commerce Department's questionnaire will detail exactly which physical characteristics need to be reported and how. Although conceptually such an exercise is straightforward, foreign companies often encounter a couple of difficulties.

 

 First, the Commerce Department often requests reporting of certain product characteristics that are not retained in the company's shipment databases, but rather can only be found in the company's production records. (For example, in many steel cases the Commerce Department questionnaire requires that the yield strength for each shipment be reported.) The company will therefore be required to 'marry' its production databases with shipment/sales databases. This often is a hugely time-consuming exercise.

 

Second, the Commerce Department's questionnaire often requests product characteristic information that the company does not retain for individual shipments. In such a situation, the company should attempt to provide a best guess based on other available information about the shipment.

 

The other very important aspect is always to remember that these product characteristics must be based on some verifiable source of information. Since these characteristics often determine whether a product is subject or not subject to the investigation (for example, whether the product fits the definition of `carbon' rather than 'alloy' steel), the Commerce Department often investigates the product characteristics closely at verification. Foreign companies need to keep this point in mind as they assemble data. Often companies have the necessary detailed data, but only retain the data for 6 or 12 months; when the verification comes, the data have been purged from computer systems or thrown away from paper records. It is important to save the data the company will need at the verification.

 

Source: Business Guide to Trade Remedies in the United States: Anti-dumping, countervailing and safeguards legislation practices and procedures