Organization Name:

Note: Representatives submitting on behalf of an organization must enter information below.

Requestor Representative:

Section 301 Investigation: China's Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation - Form to Request Exclusion of Product

When submitting a product exclusion request using this form, enter the specified 

information in the following fields and explain the basis and rationale for your statements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge. 

1. Indicate whether the comment contains business confidential information (BCI), is a public

document, or is a public version of a BCI document.

3.

2. Please provide a complete and detailed description of the product of concern:

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

10-digit HTSUS item number* for product you wish to address in this product exclusion request:

Use numerical characters only with no special characters (example: 1023456789). For help in finding 

the HTSUS item number associated with your product, see https://hts.usitc.gov/

1

7.

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential

information (BCI), is a public document, or is a public version of a BCI document.

VERSION 1

Requestor Information

Requestor Name (Last, First):

Public Version of BCI

The product is a gray iron counterweight casting utilized on vehicles in the Aerial Work Platform

industry with dimensions of LWH 19.7 x 82.5 x 40 and a weight of 8925 lbs. The product is painted with

yellow primer. EQI’s part number for this product is [ ]. Gray iron counterweight castings are

produced using a Vacuum Molding process from Class 20 Gray Iron (ASTM A48), as described in the

comments attached to this submission

8431200000 Phillips, Blake EQI, Ltd. Teresa Polino, Arent Fox LLP Importer YES Public Version of BCI
END 2

8. Is this product, or a comparable product, available from sources in the United States?:

VERSION 1

11. Please provide information in support your request, taking account of the instructions

provided in Section B of the Federal Register notice (note: text entered below can extend

beyond the apparent size of this box).

9. Is this product, or a comparable product, available from sources in third countries?:

10. Please provide the value and quantity (with units) of the Chinese-origin product of concern

that you purchased for each calendar year specified. Limit this figure to the products

purchased by your firm (or by members of your trade association) alone. Please provide 

estimates if precise figures are unavailable.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:

NONO [ ] [ ] MT [ ] [ ] MT [ ] [ ] MT

See attached for arguments in support of this request. U.S. Customs and Border Protection will be

able to administer this exclusion request based on the following information:

• The description on the Commercial Invoice from EQI’s Chinese suppliers reads “Origin China,

Counterweight” and includes the part number listed above. The part number is also printed on the

packing list and on the counterweight itself.

• Bills of Lading from EQI’s Freight Forwarder lists the description as “Counterweight” and

references the HTSUS code 84312000

• The product is painted with yellow primer. Pictures of the loaded counterweight castings and/or

container for this specific part number are included below:
 

 

Finished Part

Container
5797 Harvey St., Suite D, Norton Shores, Michigan 49444 T 616/850-2630 F 231/798-3724

AFDOCS/16668192.1

September 11, 2018

VIA REGULATIONS.GOV PUBLIC VERSION

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516

Washington, D.C., 20006

Re: Request for Exclusion of Gray Iron Counterweight Castings Classified under HTS 

8431.20.0000 from the Determination of Action Pursuant to Section 301

Dear Ambassador Lighthizer:

EQI, Ltd. (EQI) respectfully submits this request for exclusion of gray iron counterweight 

castings from the proposed determination of action pursuant to Section 301 of the Trade Act of 

1974.1 In accordance with the USTR’s instructions, we respectfully request that certain 

information contained in this submission, identified by brackets, be afforded business 

confidential treatment.2 The undersigned certifies that disclosure of the information identified in 

brackets in the confidential version of this submission would endanger the trade secrets and 

profitability of EQI and would not customarily be released to the public.

Established in 2004, EQI provides tailored Design, Engineering, Procurement, and 

 1 19 U.S.C. § 2411. 

2 Procedures To Consider Requests for Exclusion of Particular Products From the 

Determination of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related 

to Technology Transfer, Intellectual Property, and Innovation, 83 Fed. Reg. 32,181, 32,183-84 

(USTR July 11, 2018) (“Procedures To Consider Requests for Exclusion”).
PUBLIC VERSION Page 2

Logistics services to a broad base of U.S. Original Equipment Manufacturers (OEMs) in the 

heavy equipment and industrial markets. EQI is headquartered in Norton Shores, Michigan and 

currently employs 28 salaried and fully benefited engineers, quality, sales, finance, customer 

service, and operations personnel. 

EQI primarily sells gray and ductile iron, steel, and aluminum castings. This exclusion 

request addresses gray iron counterweight castings imported from China under HTSUS 

subheading 8431.20.00, which are currently subject to the 25% additional Section 301 tariff. A 

full description, including the end-use, dimensions, and weight, as well as the ability of U.S. 

Customs and Border Protection to administer this exclusion, is provided in the attached Section 

301 Investigation Form to Request Exclusion of Product. Please note that a separate Form has 

been submitted for each unique part number for which EQI is requesting an exclusion. 

In accordance with the procedures released by the Office of the United States Trade 

Representative (USTR),

3 EQI provides the following information requested by the USTR in 

support of this request. 

1. A complete and detailed description of the product of concern

As noted above, we have filed a separate Section 301 Investigation Form to Request 

Exclusion of Product for each part number for which we are requesting an exclusion. The 

specific details, including the dimensions and chemical composition unique to each part number, 

are included in the exclusion request form for that part number accompanying this attachment. A 

detailed description of the chemical composition and production produces for all counterweight 

castings classified under HTSUS 8431.20.0000 is also provided below. 

 3 Procedures To Consider Requests for Exclusion, 83 Fed. Reg. at 32,182-83.
PUBLIC VERSION Page 3

Gray iron counterweight castings classified under HTSUS 8421.20.0000 are utilized on

vehicles in the material handling and aerial work platform industries. The photos below provide 

examples of the counterweights imported under this classification. A photo of the specific 

counterweight that is the subject of this request subject is pictured above.

Figure 1: Figure 2:

The product is produced using a unique process called the Vacuum Molding process (or 

V-Process). This production method employs a sand mold that contains no moisture or binders. 

The internal cavity of the mold holds the shape of the casting due to forces exerted by the 

pressure of a vacuum. The molten iron is poured into the cavity in the mold, solidifies, and the 

vacuum is released. The V-Process is efficient as the sand can be re-used multiple times with 

minimal post-cast processing. Significant cost savings stem from the absence of resin used as a 

binder to create the mold. The process was invented in Asia, and to a large extent, remains there. 

Gray iron counterweight castings are made from Class 20 Gray Iron (ASTM A48) of the 

following properties and chemical composition:
PUBLIC VERSION Page 4

Table 1: Properties of ASTM A48 Class 20 Gray Iron

Table 2: Chemical Composition of ASTM A48 Class 20 Gray Iron

Counterweights range in size depending upon application and can weigh up to several 

thousand pounds for larger equipment. Most gray iron counterweight castings are imported into 

the U.S. in a semi-finished state, which would include the base iron casting, with some amount 

of machining, coated with either an auto-body type filler material and/or primer/finish paint. 

2. The ability of US Customs and Border Protection (CBP) to administer the exclusion 

As noted above, we have filed a separate Section 301 Investigation Form to Request 

Exclusion of Product for each part number for which we are requesting an exclusion. The 

specific details on the ability of CBP to administer each separate exclusion, including 

photographs of the unique product at shipment, are included in the exclusion request form for the 

part number accompanying this attachment. A more general description applicable to all 

counterweight castings classified under HTSUS 8431.20.0000 is also provided below. 

Counterweight castings imported by EQI from China are shipped via ocean freight from 

several Chinese ports to the United States in Full Container Loads (FCL). Each 20’ shipping 

container is filled with a one single EQI customer part number. The castings themselves are 

Class Tensile

strength 

Compressive

strength 

Tensile 

modulus E

20 22 ksi 83 ksi 10 Mpsi

Component Elements % Composition

Carbon, C 3.25 - 3.5 %

Copper, Cu 0.15 - 0.40 %

Iron, Fe 91.9 - 94.2 %

Manganese, Mn 0.50 - 0.90 %

Silicon, Si 1.8 - 2.3 %

Other elements (Cr, S, Moly, etc) Balance
PUBLIC VERSION Page 5

mounted on custom fabricated shipping racks and are marked with EQI customer part number, 

place of manufacture, manufacture date, and should this exclusion request be granted, the 

HTSUS code 8431.20.00. The counterweight castings themselves range in size from 12” to over 

7’ in length and up to 4’ in height. Counterweights, depending on their design and intended use 

can weigh as little as 100lbs to well in excess of several metric tons. EQI’s counterweight 

castings are either painted a primer black or a light primer yellow in color, depending upon 

customer specifications. The description on the Commercial invoice from EQI’s Chinese 

suppliers reads “Origin China, Counterweight”. Bills of Lading from EQI’s Freight Forwarder 

lists the description simply as “Counterweight” or “Counterweight for Fork-Lift Truck” and 

further references the HTSUS code 8431.20.00.

3. Availability of the product outside of China, i.e. whether the particular product 

and/or a comparable product is available from sources in the United States and/or 

in third countries;

There is no alternative source of gray iron counterweight castings in the quantity and 

tonnage EQI requires outside of China. Gray iron counterweight castings are unavailable in 

United States or other third countries at the scale necessary to supply U.S. demand. During the 

late 1990s, production capacity and capability to make gray iron counterweight castings shifted 

offshore as foundries in the United States were converted to manufacture higher complexity 

castings, often from other metals, or shuttered completely. According to industry experts, it is 

estimated that over 75% of the global capacity to produce gray iron counterweight castings now 

resides in China, with only one capable counterweight foundry remaining in operation in the 

U.S. The sole U.S. foundry, North Vernon Industry Corporation (NVIC), is wholly owned, 

operated, and subsidized by Toyota for the manufacture of its own gray iron counterweight 

castings for Toyota branded lift trucks. This Toyota facility is neither capable, nor willing, to 
PUBLIC VERSION Page 6

support the several hundred thousand metric tons of counterweight demand required by the 

sizeable U.S.-based OEM production base for this equipment. Alternatives to the vacuum 

molding casting process exist in the United States for iron castings, but there is not sufficient 

capacity to domestically produce the quantity required by the U.S. market.

Since the large majority of global counterweight production resides in China, U.S. OEMs 

manufacturing lift trucks and aerial work platforms, who depend on a consistent and reliable 

supply of gray iron counterweight castings, have no other viable large-scale option from where 

they can source counterweights other than China. As mentioned previously, domestic V-Process 

casting capacity outside of NVIC does not exist. Other global sourcing opportunities (in India, 

SE Asia, and even Europe) are either inadequately sized to meet US demand or too immature to 

be capable, even at lower tonnages, to supply U.S. OEMs for several years, if at all. 

Specifically, EQI has partnered with its Chinese suppliers since its formation in 2004 and 

has invested significant time, energy, and effort in developing strategic relationships to meet the 

demanding qualifications of U.S. OEM customers. EQI operates a wholly owned foreign 

enterprise in China that employs over 45 workers who monitor foundry suppliers and work to 

develop their capabilities, processes, and monitor production. EQI engages with suppliers 

constantly on training and foundry development initiatives, including LEAN manufacturing 

techniques, foundry process control, metallurgy, dimensional inspection techniques, tooling and 

fixturing, and gating design. As a result, EQI’s suppliers produce exactly what U.S. customers 

require, thus allowing EQI to best meet the needs of their customers. 

Developing the qualified suppliers necessary to provide gray iron counterweight castings 

suitable for EQI’s OEM customers requires substantial time and resources. For example, [
PUBLIC VERSION Page 7

]. 

In short, gray iron counterweight castings in the quantity and tonnage required by the 

U.S. market are only available in China. Moreover, there is no reasonable alternative or 

“comparable product” that can be used as a substitute for gray iron counterweight castings that 

will meet stringent safety, quality, aesthetic, and usability requirements of U.S. OEMs. These 

castings are not optional equipment for the vehicles produced by U.S. heavy equipment OEMs. 

Gray iron counterweight castings are required to safely and efficiently operate this equipment 

and to fulfill its intended use. 

4. Whether the imposition of additional duties on the particular product would cause 

severe economic harm to the requester or other US interests

The imposition of a 25% tariff on gray iron counterweight castings causes severe 

economic harm to EQI and other U.S. interests, including EQI’s OEM customers, which employ 

thousands of Americans in the Midwest and mid-Atlantic regions, centers of U.S. production that 

depend on a reliable supply of gray iron counterweight castings. 

As previously mentioned, EQI’s business in Norton Shores, Michigan provides 28 

salaried and fully benefited jobs. The increased duties will ultimately result in declining revenue, 

market contraction, and eventually layoffs at EQI’s Michigan offices. Moreover, following 

importation, gray iron counterweight castings are further processed and finished in the United 

States at EQI’s domestic supply chain partners in Pennsylvania, Kentucky, Virginia, Iowa, 

Indiana, and Illinois before being sold. The 25% tariff will have a negative downstream impact 
PUBLIC VERSION Page 8

on these U.S. companies, many of which, like EQI, are small- and medium-size businesses, 

reducing their sales, profitability, employment outlook, production output, capital spending, and 

investment plans.

Gray iron counterweight castings are sold to customers in the material handling and aerial 

work platform industries, which each provide hundreds of additional manufacturing jobs. In 

2017, EQI delivered nearly [ ] of castings to its customers in the United States, 

including Crown Equipment Corporation, Gradall Industries Inc., Hyster-Yale Group, Inc., and 

JLG Industries, Inc. EQI’s OEM customer base employs approximately 30,000 Americans 

domestically in regions that need high quality manufacturing jobs. This number does not include 

the larger and more impactful number of employees working for the OEM’s Tier one and other 

sub-Tier suppliers who supply domestically produced equipment. As detailed in the letters of 

support from our customers, included as Exhibit 1 to this exclusion request, the impact of the 

25% tariff on gray iron counterweight castings will ultimately be economic contraction 

throughout the supply chain, resulting in fewer Americans working in these high-quality 

manufacturing jobs. 

The 25% tariff on gray iron counterweight castings has led to dramatic increases in EQI’s 

prices from its supply chain partners, forcing us to, in turn, increase prices to our OEM 

customers. [

 ]. It remains to be seen whether our 

customers will absorb the cost increase themselves, threatening their continued profitability and 
PUBLIC VERSION Page 9

operations, or pass this increase along to their end customers, negatively impacting American 

consumers. 

An exclusion for gray iron counterweight castings from the 25% Section 301 tariff will 

benefit U.S. interests, including the long-term viability of EQI, its OEM customers, and centers 

of U.S. manufacturing in the mid-Atlantic and mid-Western regions that depend on a reliable 

supply of gray iron counterweight castings for their material handling and aerial work platform 

equipment.

5. Whether the particular product is strategically important or related to “Made in 

China 2025” or other Chinese industrial programs

Gray iron counterweight castings are neither strategically important, nor related to “Made 

in China 2025” or any other Chinese industrial program. While gray iron counterweight castings 

are themselves critical, they are ultimately a commodity product and the technology required to 

produce them has no bearing on any existing U.S. – China technology dispute or claim. 

If the purpose of the Section 301 tariff is to change China’s behavior regarding 

intellectual property and technology transfer, the current tariff on gray iron counterweight

castings is a misguided and completely unrelated product category to achieve those objectives. 

EQI’s relationships with many of its Chinese suppliers span more than 14 years since EQI’s 

inception in 2004. While EQI has developed strategic relationships with its suppliers, it 

maintains no ownership in Chinese foundries and does not purchase capital equipment or raw 

materials for their exclusive use. There is no relevant intellectual property associated with these 

commodity products and EQI has never been asked nor required by the Chinese government or 

any other non-governmental Chinese organization to provide any assistance that would not itself 

benefit EQI or its customers. Indeed, rather than transfer technology, where Chinese machinery 
PUBLIC VERSION Page 10

or inputs have been inferior, EQI has arranged for those materials to be sourced from the United 

States. [ 

 ].

Moreover, the 25% tariff will not protect, grow, or otherwise change the domestic 

foundry industry as it relates to gray iron counterweight castings. Given the large capital 

investment required and small profit margin for gray iron counterweight castings, new 

counterweight foundry capacity is not being built in the U.S. and likely never will be. The return 

on investment is simply too long and the margin on this commodity product too narrow to justify 

the expense. The likelihood that major capital investments will be made based solely on the 

benefit that the tariff might provide to the domestic foundry industry is virtually zero, as any 

tariff can easily be reversed in the future by a subsequent administration.

Finally, as detailed above, the imposition of a 25% tariff on gray iron counterweight 

castings does not serve Section 301’s stated purpose of eliminating China’s discriminatory acts, 

policies, and practices. Because gray iron counterweight castings are only available from China, 

U.S. OEMs have no choice but to continue to make purchases from the China-based supply 

chain. A tariff on this product will not drive changes in Chinese trade behavior or the purchasing 

patterns of U.S. OEM consumers; gray iron counterweight castings will continue to be purchased 

in China regardless of the tariff, which simply functions as a penalty tax on U.S. manufacturers 

who require counterweights for their products.

We appreciate the Department’s consideration of this exclusion request. Please contact 

the undersigned if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my 
PUBLIC VERSION Page 11

knowledge.

Respectfully submitted,

Blake Phillips

President and CEO

EQI, Ltd. 
 Exhibit Exhibit 11 
mown Equipment Corporation 

44 S. Washington Street 

New Bremen, OH 45869 USA 

Tel 419 629 2311 Fax 419 629 3256 

john.taleOcrown.com 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, DC 20508 

RE: Support for the Removal of Counterweight Castings from 

USTR's List of Products Subject to Section 301 Tariffs 

Dear Secretary Lighthizer: 

John E. Tate' 

April 30, 2018 

Crown Equipment Corporation is a customer of EQI, Ltd. We purchase 

counterweight castings through EQI's facilities in Norton Shores, MI. We are 

writing this letter in opposition to the proposed additional 25 percent tariffs on 

counterweight castings pursuant to Section 301 of the Trade Act of 1974. 

Imposition of such high tariffs on counterweight castings would cause significant 

harm to U.S. interests, including our employees and our customers, while doing 

little to eliminate China's discriminatory acts, policies, and practices. 

Crown is one of the world's largest material handling companies with a 

reputation for award-winning product design, advanced engineering and 

technology, and superior after-sale service. Crown's business philosophy utilizes 

vertically integrated processes to design, manufacture and distribute forwardthinking, innovative solutions that improve customers' productivity and operating 

efficiency. Crown produces a broad range of forklifts as well as automation and 

fleet management technologies. 

The company's global headquarters is located in New Bremen, Ohio, U.S.A. Its 

employees number more than 15,000 worldwide and 9,000 in over 75 U.S. 

locations. Crown operates a service and distribution network that exceeds 500 

retail locations in over 80 countries. We have been a regular customer of 

counterweight castings for lift trucks from EQI for more than 10 years. 

Crown is dependent on a reliable and reasonably priced supply of counterweight 

castings. EQI is one of the few suppliers of counterweight castings that 

consistently meets our precise specifications and needs. We have found EQI to 

be our best option for counterweight castings given its technical capabilities, 

consistent quality, and timely deliveries. We are unaware of any U.S. 

manufacturer of such counterweights from whom we could source these 

products at the volumes and quality levels required by our operations. Any 

disruptions to EQI's diversified supply chain, including the imposition of these 

tariffs, will result in serious inefficiencies and increased costs for our business. 
mown Equipment Corporation 

44 S. Washington Street 

New Bremen, OH 45869 USA 

Tel 419 629 2311 Fax 419 629 3256 

john.tatericrown.com 

John E. TaW 

Page 2 April 30, 2018 

The imposition of a 25 percent tariff on imported counterweight castings could 

significantly increase EQI's cost of production, which would increase the price of 

our purchases. In anticipation of these increased costs, we are concerned for 

our business and our employees. The rise in costs resulting from these tariffs will 

significantly increase our costs and inhibit Crown's competitive position against 

foreign imports. 

We respectfully request that the Department exclude counterweight castings 

from the proposed list of products covered by the 25 percent tariffs pursuant to 

Section 301. We believe this is in the interests of U.S. businesses like Crown and 

American manufacturing jobs. 

I certify that the above statements are true and accurate to the best of my 

knowledge. 

John E. Tate 

Senior Vice President 

JET:plg 

cc: Warren Davidson 

Jim Jordan 

Bob Latta 

Rob Portman 

Mike Turner 
GRADALL 

GRADALL INDUSTRIES, INC. 

April 25, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

Re: Support for the Removal of Counterweight Castings and Steel Castings from USTR's List of 

Products Subject to Section 301 Tariffs 

Dear Secretary Lighthizer: 

Gradall Industries, Inc. is a customer of EQI, Ltd. We purchase counterweight castings and steel 

castings through EQI's facilities in Norton Shores, MI. We are writing this letter in opposition to 

the proposed additional 25 percent tariffs on counterweight castings pursuant to Section 301 of 

the Trade Act of 1974. Imposition of such high tariffs on counterweight and steel castings would 

cause significant harm to U.S. interests, including Gradall, our employees, and our customers, 

while doing little to eliminate China's discriminatory acts, policies, and practices. 

Gradall Industries, Inc. is a manufacturer of Gradall hydraulic excavators, and Vacall vacuum & 

water jet trucks located in New Philadelphia OH, and is a wholly-owned subsidiary of Alamo 

Group, Inc. of Seguin TX, a world leader in the design, distribution, and service of high quality 

equipment for right-of-way maintenance and agriculture. We employ over 3000 at 30 different 

locations worldwide. We have been a regular customer of cast counterweights and steel castings 

from EQI for over 12 years. 

Gradall is dependent on a reliable and reasonably priced supply of counterweight and steel 

castings. EQI is one of the few suppliers of counterweight and steel castings that consistently 

meets our precise specifications and needs. We have found EQI to be our best option for 

counterweight and steel castings given its technical capabilities, consistent quality, and timely 

deliveries. We are unaware of any US manufacturer of such counterweights from whom we 

could source these products at the volumes and quality levels required by our operations. Any 

disruptions to EQI's diversified supply chain, including the imposition of these tariffs, will result 

in serious inefficiencies and increased costs for our business. 

The imposition of a 25 percent tariff on imported counterweight and steel castings could 

significantly increase EQI's cost of production which would increase the price of our 

purchases. In anticipation of these increased costs, we are concerned for our business and our 

employees. Gradall has 340 employees located in New Philadelphia OH. The significant rise in 

1 

406 Mill Avenue SW, New Philadelphia, Ohio 44663 • Telephone 330.339.2211 • Fax 330.339.8468 • www.gradall.com 

A--
GRADALL 

GRADALL INDUSTRIES, INC. 

costs resulting from these tariffs will directly impact our ability to compete in a global market 

and would impact our total sales, profitability, and could result in loss of jobs in our local 

community. 

We respectfully request that the Department exclude counterweight castings and steel castings 

from the proposed list of products covered by the 25 percent tariffs pursuant to Section 301. We 

believe this is in the interests of U.S. businesses like Gradall and American manufacturing jobs. 

I certify that the above statements are true and accurate to the best of my knowledge. 

Michael A. Haberman 

President 

Gradall Industries, Inc. 

2 

406 Mill Avenue SW, New Philadelphia, Ohio 44663 • Telephone 330.339.2211 • Fax 330.339.8468 • ‘mw.gradall.com 

A--
HYSTER-YALE 

GROUP 

May 9, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

Re: Support for the Removal of Counterweight Castings from 

USTR's List of Products Subject to Section 301 Tariffs 

Dear Secretary Lighthizer: 

Hyster-Yale Group, Inc. ("HYG") is the operating subsidiary of Hyster-Yale Materials Handling, Inc., a 

Cleveland, Ohio-based leading, globally integrated, full-line lift truck manufacturer. HYG designs, 

engineers, manufactures, sells, and services a comprehensive line of lift trucks and aftermarket parts 

marketed globally, primarily under the Hyster® and Yale® brand names. HYG employs 

approximately 6,800 employees worldwide, and its revenues at the end of 2017 were $2.9 billion. 

Hyster-Yale Group ("HYG") has been a customer of EQI, Ltd. ("EQI") since 2006. HYG purchases 

counterweight castings through EQI's facilities in Norton Shores, MI. This letter is written in 

opposition to the proposed additional 25 percent tariffs on counterweight castings pursuant to 

Section 301 of the Trade Act of 1974. Imposition of such high tariffs on counterweight castings 

would cause significant harm to U.S. interests, including HYG, our employees, and our customers, 

while doing little to eliminate China's discriminatory acts, policies, and practices. 

HYG is dependent on reliable and reasonably priced suppliers of counterweight castings. EQI 

supplies counterweight castings to HYG that have consistently met our specifications and needs. 

Any disruption to EQI's diversified supply chain, including the imposition of these tariffs, will result 

in potential increased costs for our business. 

EQI has informed HYG that the imposition of a 25 percent tariff on imported counterweight 

castings could significantly increase EQI's cost of production, which would increase the price 

of HYG purchases. In anticipation of these increased costs, HYG is concerned for our business and 

UTILEV' NUVERA 

Hyster-Yale Group, Inc. 1400 Sullivan Drive, Greenville, NC 27834 

www.hyster-yale.com 

1111.1111111111.111 
HYSTER-YALE 

GROUP 

our employees. The rise in costs resulting from these tariffs will impact not only EQI but other 

American businesses. As suppliers such as EQI pass these additional costs to their customers (i.e. 

HYG), we then must pass these costs to our customer base, many of which are American-based 

businesses purchasing from American-based manufacturers. 

HYG respectfully requests that the Department exclude counterweight castings from the proposed 

list of products covered by the 25 percent tariffs pursuant to Section 301. We believe this is in the 

interest of U.S. businesses like HYG, EQI, and American manufacturing jobs. 

I certify that the above statements are true and accurate to the best of my knowledge. 

Very truly yours, 

Mark Ch pagn 

Director of Supply Chain - Americas 
N E P 

NORCA ENGINEERED PRODUCTS 

April 26, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

8224 CREEDMOOR ROAD SUITE 201 

RALEIGH, NORTH CAROLINA USA 27613 

PHONE: 919-846-2010 

FAX: 919-846-3814 

EMAIL: mail@norcaeng.com 

WEBSITE: www.norcaeng.com 

Re: Support for the Removal of Counterweight Castings from USTR's List of Products Subject to Section 301 

Tariffs 

Dear Secretary Lighthizer: 

We are writing this letter to express our support for EQI, Ltd.'s efforts to have counterweight castings, 

classified under subheadings 8431.20.0000, 8431.41.0000, 8431.49.9095, and 8431.49.9010 of the Harmonized 

Tariff Schedule, removed from the USTR's list of products subject to a 25 percent ad valorem tariff pursuant to 

Section 301. 

Like EQI, Norca Engineered Products LLC (NEP) is a U.S. supplier that imports counterweight castings from 

China for use in the U.S. market. NEP is located in Raleigh, North Carolina with sales in excess of usd 100 

million serving large manufacturers in North America. Because counterweight castings are generally not 

produced in the U.S., we source counterweight castings from our unaffiliated iron casting supplier in China. 

Our customer is located in the Midwest, where they manufacture 100 percent of mini excavators and skids 

steers; we supply 100 percent of their demand for counterweights. 

We are concerned the proposed tariffs on counterweight castings harm our U.S. customer, who depends on us 

for a reliable supply of counterweight castings. We will be forced to pass along 100 percent of the tariff cost to 

our USA customer due to the low profit margins required to compete in this industry. 

Because counterweight casting capacity is concentrated outside the United States, our customers have no 

alternative and must simply bear these additional costs, or pass them on to their customers; in either instance, 

there will be significant resulting economic hardship, which could sharply impact their export markets in 

Canada, Central America, South America and Asia. 

In consideration of the above, we offer our full support for EQI's submission, which is reflective of the industry 

as a whole. The Department should remove counterweight castings from the proposed list of products to be 

covered by the Section 301 tariffs. 

I certify that the above statements are true and accurate to the best of my knowledge. 

/s/ Plf t

Jame ollan 

Presi ent 

Norca Engineered Products 
JAE 

reachingout. 

April 23, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

JLG Industries, Inc. 

13712 Crayton Boulevard 

Hagerstown, MD 21742-2386 

TEL: 240.420.2661 a FAX: 240.313.1862 

jIg.com 

An Oshkosh Corporation Company 

Re: Support for the Removal of Counterweight Castings from USTR's List of Products Subject to Section 301 

Tariffs 

Dear Secretary Lighthizer: 

JLG Industries, Inc., a subsidiary of Oshkosh Corporation, is a customer of EQI, Ltd. We purchase 

counterweight castings through EQI's facilities in Norton Shores, MI. We are writing this letter in support of 

EQI's request for an exemption to the proposed additional 25 percent tariffs on counterweight castings 

pursuant to Section 301 of the Trade Act of 1974. Imposition of such tariffs on counterweight castings would 

cause significant harm to U.S. interests, including JLG, our employees, and our customers. 

JLG is a manufacturer of aerial work platforms and material telehandlers, headquartered Hagerstown, 

Maryland. JLG is dependent on a reliable and reasonably priced supply of counterweight castings. EQI is the 

only US supplier of counterweight castings that consistently meets our precise specifications and needs. We 

have found EQI to be our best option for counterweight castings given its technical capabilities, consistent 

quality, and timely deliveries. We are unaware of any US manufacturer of such counterweights from whom 

we could source these products at the volumes and quality levels required by our operations. 

The imposition of a 25 percent tariff on imported counterweight castings could significantly increase EQI's 

cost of production which would increase the price of our purchases. In anticipation of these increased costs, 

we are concerned on the impact on our business, our customers and our employees. 

We respectfully request that the Department exclude counterweight castings from the proposed list of 

products covered by the 25 percent tariffs pursuant to Section 301. We believe this is in the interests of U.S. 

businesses like JLG and American manufacturing jobs. 

I certify that the above statements are true and accurate to the best of my knowledge. 

ran enhausen 

EVP Oshkosh Corporation & 

President, JLG Industries, Inc. 
OLYMPIC FOUNDRY ! QUALITY CASTINGS SINCE 1900 I 

May 10, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

Olympic Foundry 

QUALITY CASTINGS SINCE 1900 

Re: Support for the Removal of Counterweight Castings from USTR's List of Products Subject 

to Section 301 Tariffs 

Dear Secretary Lighthizer: 

We are writing this letter to express our support for EQI, Ltd.'s efforts to have counterweight 

castings, classified under subheadings 8431.20.0000, 8431.41.0000, 8431.49.9095, and 

8431.49.9010 of the Harmonized Tariff Schedule, removed from the USTR's list of products 

subject to a 25 percent ad valorem tariff pursuant to Section 301. 

Like EQI, Olympic Foundry, Inc is a U.S. supplier that imports counterweight castings from 

China for use in the U.S. market. Olympic Foundry, Inc is a Seattle-based company specializing 

in the manufacturing management of foundry products such as counterweights for distribution to 

Original Equipment Manufacturers (OEMs) primarily in the US market. With annual sales in 

excess of $100MM, Olympic Foundry is an important and substantial provider of import castings 

within this market segment. Because counterweight castings are generally not produced in the 

U.S., we source counterweight castings from our Joint Venture Foundry in China. These import 

counterweight castings are used by OEMs in the manufacture of equipment for the construction, 

agricultural, crane, forklift, man and material lift, and gas and oil industries by companies such 

as Terex, Caterpillar, Manitowoc, Case New Holland, and General Electric. 

In anticipation of increased costs, we are concerned for our business and our employees. Our 

company has 60 full time and fully benefited employees located in Washington, Oregon, Idaho, 

Oklahoma, Minnesota, and Iowa. The rise in costs resulting from these tariffs could be 

catastrophic to our business as our facilities and employees are strategically located to provide 

goods and services to the OEM community. Should these proposed tariffs be implemented, it is 

not a question of whether U.S. jobs at Olympic will be lost, it is a question of how many and to 

what degree in each market segment. 

But the impact to companies like Olympic Foundry and EQI, and the affect to our employees, is 

only the tip of the ice burg. The imposition of these tariffs will harm our U.S. customers who 

depend on us for a reliable and sustainable supply of counterweight castings. Olympic Foundry 

will be forced to pass the added costs of tariffs on to our U.S. customers who, in our estimation, 

will simply be forced to absorb a portion and pass the rest to end-users in the marketplace. The 

resulting economic impact to these much larger employers with equipment manufacturing 

located throughout virtually all the various regions of the U.S. could be staggering. 

piEffe .opq 

Divisions of Olympic Foundry 

www.olympicfoundry.com 

SEATTLE 

main 206.764.6200 

fax 206.764.1170 

5200 Airport Way South 

Seattle, WA 98108 
OLYMPIC FOUNDRY1QUALITY CASTINGS SINCE 1900 

Olympic Foundry 

QUALITY CASTINGS SINCE 1500 

Olympic Foundry, Inc also manages the manufacturing of various engineered and machined 

industrial castings for our OEM customers and procures these castings from many countries of 

origin including and especially the U.S. today. With this direct experience and knowledge, we 

recognize the counterweight capacity necessary to support the volume needed for U.S. OEM 

demand today simply does not exist in the U.S., nor is it an attractive investment to create it. 

The ratio of raw material vs value added processes vs available profit margin makes the products 

themselves an unattractive proposition in the U.S. manufacturing environment. And those low 

profits would only be realized after the huge capital investments to build foundries of the size 

and sort to make these large, heavy, and tolerance critical counterweights. An investment of this 

required enormity would likely never be recouped, especially after the ongoing repair and 

maintenance required to own and operate a U.S. counterweight foundry. 

Please also know Olympic Foundry, Inc. was a producing foundry in Seattle, Washington from 

the year 1900 until its closure in 1986. As with many other large casting foundries, Olympic 

Foundry was closed in 1986 due primarily to ever-increasing environmental compliance costs, 

the ever-increasing impact of repair and maintenance on a large foundry, and shrinking 

profitability due to the affects of globalization in the latter half of the 20th century. Having lived 

that reality, and since filling and growing a strong and necessary import counterweight market 

niche, should these counterweight casting tariffs be introduced, the very last thing Olympic 

Foundry will be doing is building a new counterweight foundry in the U.S as a result. It still 

simply does not make sound financial sense for Olympic or others to do so. 

Since counterweight casting capacity is concentrated outside the United States, our customers 

have no alternative and must simply bear these additional costs, or pass them on to their 

customers; in either instance, there will be significant resulting economic hardship throughout 

the entire supply chain. 

In consideration of the above, we offer our full support for EQI' s submission, which is reflective 

of the industry as a whole. The Department should remove counterweight castings from the 

proposed list of products to be covered by the Section 301 tariffs. 

I certify that the above tatements are true and accurate to the best of my knowledge. 

/s/ 

Sc tt Laug 

President and COO 

IL 1L",70=Joss -1-1_77 sPri 

SEATTLE 

main 206.764.6200 

fax 206.764.1170 

Divisions of Olympic Foundry 

www.olympicfoundry.com 

5200 Airport Way South 

Seattle, WA 98108