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):
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:
THE HONORABLE ROBERT LIGHTHIZER

U.S. TRADE REPRESENTATIVE

EXECUTIVE OFFICE OF THE PRESIDENT

600 17TH STREET, NW

WASHINGTON, DC 20006

Subject: Docket number USTR-2018-0025

Request for exclusion of Healthy Air Inc Portable Air Purification System

Under HTS classification 8421.39.8015 from the Determination of Action

Pursuant to Section 301: China’s Acts, policies, and Practices Related to Technology Transfer, Intellectual

Property and Innovation

Dear Ambassador Lighthizer,

Healthy Air Inc. is a family owned Florida start-up company, that was founded in May 2013. The single focus of

the company is to design, market and sell a line of branded Healthy Air® Air Purification Systems that

incorporate proprietary eHEPA® technology that is covered by US patent and trademark rights.

Healthy Air® eHEPA® technology couples electrostatic augmentation of filter media, to enhance contaminate

capture efficiency, with enhanced catalytic oxidation and adsorption of Volatile Organic Compounds (VOC).

Healthy Air novel eHEPA® technology not only captures the contaminates including microorganisms such as

virus, bacteria and molds, it also kills and destroys these dangerous microorganisms by exposing them to high

voltage electric field.

Since 2013, Healthy Air Inc has contracted with (BCI) company in China to make product design and prototyping

based on the conceptual design provided by Healthy Air Inc. The Chinese company then sources and

manufactures our Air Purification products for specific applications in an effective and cost-efficient manner.

Since inception, these products have been imported to the US by Healthy Air Inc and have been marketed and

sold throughout the US and Canada either directly by Healthy Air Inc, or by licensed distributors. We engaged

the Chinese company for further design, prototyping and manufacture of our patented concept because it was

not possible to afford to make these in US due to high labor cost, high tooling costs, low production volumes (50

units/run), and high cost of molding for the plastic parts.

Over the past five (5) years we have looked for alternative manufacturing sources in US, but we have been

unable to find a company that would provide us with comparable engineering, prototype development and low

quantity manufacturing services at a price that comes close to what we currently pay this Chinese company. In

short, we will be unable to maintain our business operation without manufacturing through this Chinese

company and we may be forced to scale back our operations.
The Healthy Air Portable Air Purification System is now sold to few niche markets and used for specific

applications, such as nursing homes, medical facilities, retail establishments and offices to clean the air of fine

particles and volatile organic compounds, as well as airborne microorganisms the spread infectious deceases. According to the CDC and World Health organization, the most dangerous pathogens are those that have the

potential to spread by the airborne route. Healthy Air Ceiling Mount unit is an air purification system the can

effectively capture, kill and destroy these and minimize the spread of infectious deceases in places like health

care facilities.

Our Healthy Air Portable Air Purification system is not related or relevant to the “Made in China 2025”. Healthy

Air is a US brand and we maintain our intellectual property in the US, with our own patents issued by the USPTO.

The additional 25% import duty currently imposed on our product which are manufactured in, and shipped

from, China will significantly increase our product cost and we will have no option but to increase the retail price

to the point where American workers that need this protective technology will be unable to afford it. Moreover,

the additional 25% duty will disrupt our business and significantly depress our financial health and limit our

ability to continue developing innovative and affordable solutions to help the well-being of American workers

that need this protection.

There is nothing inherently difficult about the identification of the product by CBP and this product is easily

identified by:

1: part number “HA-PAP-G2-A, HA-PAP-G2-B OR HA-PAP-G2-C” and description “Portable Air Purification

System” on the outside of the packaging and distinctive illustration of the product on the other side of the

package:

Front of Box Back of the Box
2: Package dimension of 14” x 13” x 32” 3: unit net weight of 38 lbs

4: Distinctive Logo

In Summary, Healthy Air Inc. requests that its Portable Air Purification System model HA-PAP-G2-A, HA-PAP-G2- B and HA-PAP-G2-C under classification 8412.39.8015 not be subject to 25% ad valorem duty. This product shall

not be subject to the tariff increase because doing so will harm Healthy Air Inc. business without providing any

corresponding benefit to U.S. consumers of this product.

All the information contained in this request is true and based on fact.

Sincerely,

Dr. Karim Zahedi

VP, Research and Development

T: 800-259-2535

KZahedi@Healthyair.com

www.Healthyair.com

karim zahedi