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

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

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

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correct to the best of your knowledge. 

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

1

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VERSION 1

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Law Office of

Jeffrey M. Winton PLLC

1900 L Street, N.W., Suite 611

Washington, D.C. 20036

202.774.5500

JEFFREY M. WINTON

jwinton@jmwinton.com

202.774.5503 (Direct)

202.478.1996 (Telecopy)

October 9, 2018

Docket No. USTR-2018-0025

Total Pages: 15

Public Document

PUBLIC DOCUMENT

Honorable Robert E. Lighthizer

U.S. Trade Representative

600 17th Street, NW

Washington, DC 20508

Re: Requests for Exclusion of Particular Products from Determinations of 

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

Related to Technology Transfer, Intellectual Property, and Innovation

Dear Ambassador Lighthizer:

We are writing, on behalf of New Couplings & Pups, LLC, to request that the metal 

treatment machines described below be excluded from the additional 25 percent tariff 

announced in the Determination of Action Pursuant to Section 301: China’s Acts, Policies 

and Practices Related to Technology Transfer, Intellectual Property, and Innovation.1 

A. Description of Products

These metal treatment machines are factory equipment used in the manufacturing of 

couplings. Specifically, they finish couplings after they are threaded by lathes (CNC 

Coupling Finish Machines, or lathes, are addressed in another submission). These 

 

1 Notice of Action and Request for Public Comment Concerning Proposed Determination 

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

Technology Transfer, Intellectual Property, and Innovation, 83 Fed. Reg. 28,710 (June 20, 

2018).
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 2

couplings are Oil Country Tubular Good (“OCTG”) products that meet American 

Petroleum Institute (“API”) standards for couplings. These couplings join various OCTG 

casings and tubes so that rigs can drill deep enough to reach oil. No OCTG pipe is 

individually long enough to drill wells for extraction; couplings are essential in oil drilling.

Here, we request exclusions for four metal treatment machines, all of which fall in 

HTSUS code 8479.81.0000. Two of the four metal treatment machines are magnetic flaw 

detectors. The first, ZY-CJW-4000GZB, is used to detect flaws within couplings between 

2.5” and 7” in diameter. It consists of the base machine and an electrical cabinet. The 

base machine is 4.92’ x 4.4’ x 6.56’ and the electrical cabinet is 1.97’ x 1.97’ x 4.6’. It 

also includes a 11.48’ feeding platform. The second, ZY-CJW-6000GZB, is used to detect 

flaws within couplings between 10.6” and 18.1” in diameter. It consists of a base machine

and an electrical cabinet, which are 5.25’ x 4.97’ x 6.56’ and 1.97’ x 1.97’ x 5.25’

respectively. It also consists of feeding platform that is 11.48’ in length.

The other two metal treatment machines are pneumatic marking machines. The 

marking machines, i.e., the GNQ-800-PRO and the GNQ-140Z-V, are used to add 

markings to thee exterior of the otherwise completed couplings. Both models are 13.3” x 

17.3” x 30.3” and are designed to operate with the rest of the machines covered in other 

requests.

B. About New Couplings and Pups, LLC

New Couplings and Pups, LLC, is a new venture of Amerjin Co., LLC, which has 

distributed couplings and other OCTG to pipe and tube manufacturers in the Houston area 

for more than fifteen years. Many OCTG pipe and tube manufacturers do not import or 
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 3

create their own couplings; they instead rely on importers like Amerjin to provide them 

with API-grade couplings at reasonable prices. Recently, U.S. policy put a larger emphasis 

on U.S. energy independence, raising oil prices and dramatically increased the local 

demand for OCTG products. To meet this demand, pipe and tube manufacturers have 

opened four new mills in the Houston area since 2014.2 However, local coupling 

production has not kept pace, with only one new mill opening since 2014, only partially 

mitigating the increase in demand. In 2016, seeing an opportunity to fill that market gap, 

Amerjin established New Couplings and Pups to construct and operate a new coupling 

mill. The construction of the new coupling mill began in 2017.

As a part of that new venture, New Couplings and Pups obtained and plans to import

many pieces of manufacturing equipment to get the mill up and running. In particular, it 

plans to import two GNQ-800-PROs, one GNQ-140Z-V, one ZY-CJW-4000GZB, and one 

ZY-CJW-6000GZB.

C. Reasons for Exclusion

This exclusion request is one of five applications for manufacturing equipment 

needed to operate the new coupling mill. All of these pieces of equipment are designed to 

work with one another and will have compatibility issues if paired with third-party 

equipment. As such, please consider each of these exclusion requests together. This 

exclusion in particular is appropriate and necessary because these metal treatment 

machines are (i) only available in China, (ii) not strategically important to Made in China 

 

2

See Attachment 4.
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 4

2025 or other Chinese industrial policies, and (iii) because additional duties on these

particular products would cause severe economic harm

First, these metal treatment machines are only available in China. Although other 

similar equipment exist for sale in third-countries, those are incompatible with New 

Couplings and Pups’ other equipment and accessories. These machines were assembled 

for this specific purpose. Using other equipment would not suit the particular purpose of 

New Couplings and Pups, would not fit into its business plan, nor is there a guarantee they 

would function at all. As such, forcing it to purchase an alternate set of equipment may 

prevent the venture from opening the mill altogether.

Second, these metal treatment machines are not strategically important to Made in 

China 2025 or other Chinese industrial policies. The importation of these machines does 

not contribute to the long-term economic strength of the Chinese technology sector. 

Moreover, these machines are not being imported for resale or in large quantities, they are 

being imported for use by one company, in one factory, for one purpose. New Couplings 

and Pups only intends to import five of these machines in total. These imports do not 

facilitate the growth of the Chinese technology sector, but they do aid in the growth of the 

U.S. oil industry.

Third, the tariff would inflict severe economic harm to New Couplings and Pups and 

the Houston oil industry more broadly. As mentioned above, these machines were already 

contracted for. As with any new enterprise, resources are in tight supply. Adding tariffs to 

this equipment would slow the construction of the mill and delay its operation, putting a 

strain on New Couplings and Pups’ resources. Delaying the commencement of the mill’s 
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 5

production would also deprive the Houston oil industry from an important component for 

their oil rigs. The demand for couplings in the area is only increasing, especially with the 

opening of a new pipe and tube mill next year.3 If New Couplings and Pups cannot open 

its doors to help offset the higher supply of other OCTG parts, the oversaturation of pipes 

and tubes could adversely affect the oil industry, and thus oil prices.

Furthermore, in constructing the mill, New Couplings and Pups projects that it will 

employ over 60 people. If this tariff is applied and New Couplings and Pups ceases 

construction, those jobs will not exist. 

D. Conclusion

For the reasons stated above, we respectfully request an exclusion from the Section 

301 tariffs for the GNQ-800-PROs, GNQ-140Z-V, ZY-CJW-4000GZB, and ZY-CJW6000GZB metal treatment machines. Please do not hesitate to contact us if you have any 

questions.

Respectfully submitted,

/s/ Jeffrey M. Winton

Jeffrey M. Winton

Counsel to New Couplings & Pups, LLC

 

3

See id.
List of Attachments

1. Pneumatic Marking Machine Images

2. ZY-CJW-4000GZB Magnetic Flaw Detector Blueprint

3. ZY-CJW-6000GZB Magnetic Flaw Detector Blueprint

4. Pipe and Tube Mill Buildup after 2014 in Houston Area 
Attachment 1 

Pneumatic Marking Machine Images
Model:GNQ-800-PRO Model:GNQ-140Z-V
Attachment 2

ZY-CJW-4000GZB Magnetic Flaw Detector Blueprint

Attachment 3

ZY-CJW-6000GZB Magnetic Flaw Detector Blueprint

Attachment 4

Pipe and Tube Mill Buildup after 2014 in Houston Area
Pipe and Tube Mill Buildup after 2014 in Houston Area 

1)Borusan Mannesmann Baytown Plant (2014)

300,000 Ton/Year. 

2)Axis Pipe and Tube Bryan, TX (2015)

300,000 Ton/Year. 

3)Benteler Steel-Tube Bossier City, LA (2015)

320,000 Ton/Year. 

4)Tenaris-Bay City Plant (2018)

650,000 Ton/Year. 

5)TPCOA Corpus Christi (2019)

500,000 Ton/Year 

Total Capability: 2,070,000 Tons/Year. 

New Coupling Mill since 2014 

1)Pinnacle Machine Works

New Couplings and Pups, LLC. 

7806 Richmond Ave.

Houston, TX 77063-6154

Tel: (713) 977-0243

Fax: (713) 780-0077

e-mail: xzhu6@hotmail.com

 xzhu@amerjin.com