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:
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

October 9, 2018

Ambassador Robert Lighthizer

U.S. Trade Representative

600 17th St., N.W.

Washington, DC 20508

RE: REQUEST FOR EXCLUSION OF PARTICULAR PRODUCTS FROM THE ACTION 

PURSUANT TO SECTION 301: CHINA’S ACTS, POLICIES, AND PRACTICES RELATED TO 

TECHNOLOGY TRANSFER, INTELLECTUAL PROPERTY AND INNOVATION

DOCKET USTR-2018-0025 

Request to remove HTSUS 8536.69.4030 from Section 301 tariffs.

Dear Ambassador Lighthizer:

On behalf of our client, American Mitsuba Corporation (AMC), we hereby present comments on 

your recent proposal to place a 25-percent additional duty on several imports from China, pursuant to 

your findings of the Investigation into China’s Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation Under Section 301 of the Trade Act of 1974. American 

Mitsuba Corporation respectfully submits request for a product specific exclusion for windshield wiper 

motor rack and panel connector classified under HTSUS 8536.69.4030. A formal description of the 

windshield wiper motor rack and panel connector is located below in section III. 

AMC hereby requests business confidential treatment for business proprietary information between 

single brackets in this submission. The disclosure of business proprietary information would endanger trade 

secrets or profitability, and this information would not customarily be released to the public.
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

I. Executive Summary

AMC submits that imposing a 25-percent increase duty on HTSUS 8536.69.4030 will not be 

practicable or effective in obtaining the elimination of China’s acts, policies or practices. Maintaining or 

imposing the proposed additional duties on this product will cause disproportionate economic harm to U.S. 

interests, AMC, other U.S. businesses, and U.S. consumers. It is likely that increasing the duties on this 

product and others similar to this product will increase the cost of automotive production in the U.S. and 

pass through to U.S. consumers. 

II. Overview of the Company

American Mitsuba Corporation (AMC) was established in 1986 in Mount Pleasant, Michigan. AMC is 

the largest subsidiary of Mitsuba Corporation outside of Japan and is integral to the operations of Mitsuba 

globally. [

 ]. 

AMC is a manufacturer and supplier of current-electric motors, actuators, and electrical components 

that are used in the automotive industry. AMC’s products include, but are not limited to, starter motors, 

fan Motors, armature for electronic throttle control (cruise control) motors, wiper systems, electric power 

steering motors, sunroof motors, and power window motors. AMC designs and manufactures its products 

at five operational facilities in the United States. AMC’s three manufacturing facilities are located in 

Mount Pleasant, MI, Monroeville, IN, and Bardstown, KY. AMC’s two research and development 

technical centers are located in Novi, MI and Dublin, OH. Overall, AMC employs 926. 
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

AMC imports from its sister company in China, Mitsuba Electric (Dalian) Co. Ltd. Mitsuba Electric 

(Dalian) Co., Ltd. was founded as a private company in 1993. The company's line of business includes the 

manufacturing of motor vehicle parts and accessories. 

III.Specific Product Description

Tariff Code (HTS) Detailed Description Picture

8536.69.4030 Motor Vehicle 

Windshield Wiper 

Motor Insulated 

wire harness that 

works the joint 

between the vehicle 

side wire harness 

and motor side 

coupler. 

IV.Administrability by Customs and Border Protection

The U.S. Customs and Border Protection (CBP) will be able to effectively administer and enforce this 

provision. There is nothing inherently difficult about the specifications of the product that would require CBP to 

make complex differentiations in order to administer the exclusion. In addition, AMC will ensure that its 

invoices reflect the specific terms of the nomenclature and maintain substantive and accessible records of 

import, production, and specification standards. AMC will cooperate with CBP with respect to any request for 
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

additional documentation including requests to inspect the imported merchandise and/or the production facility 

in China.

V. Annual Quantities and Value

AMC sold units per below. 

Tariff Code (HTS) Annual Quantity and Value

QTY

2015

Import 

Value

2015

QTY 

2016

Import 

Value

2016

QTY

2017

Import Value 

2017

8536.69.4030

[ ] $[ ] [ ] $[ ] [ ] $[ ]

VI.Specific Reasons Why This Product Must Be Excluded

A. This product is available only from China. 

AMC cannot shift its hardware manufacturing to a third country. Currently, AMC does not manufacture 

this windshield wiper motor rack and panel connector in any third country outside of China. Should it 

relocate all its Chinese manufacturing activities to a third country, AMC will have to either acquire a new 

facility or build an entire manufacturing facility. The expected costs of such an undertaking could be 

astronomical. 
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

In addition, AMC cannot fully move its production to the United States in an efficient manner. To 

manufacture in the United States, AMC will have to set up additional manufacturing capabilities, which 

could [ ]. Even if AMC eventually manages to shift manufacturing to the U.S., it will still 

have to import raw materials from China (since AMC cannot import them from anywhere else) and bear 

the associated costs. These additional costs will be borne by AMC’s end-user customers, which are other 

U.S. businesses, including but not limited to, U.S. automotive suppliers and dealers.

B. The imposition of additional duties on this product would cause severe economic harm to AMC 

and other U.S. businesses.

The automotive industry is one of the most important industries in the United States. It has historically 

contributed approximately 3.5 percent to the overall GDP of the United States. Any imposition of tariffs 

of 25-percent on our products would cause disproportionate economic harm to U.S. interests. A 25-

percent ad valorem duty on AMC’s product will affect a significant amount of annual imports of AMC’s 

windshield wiper motor rack and panel connector. These losses are unsustainable in the long run and will 

require AMC to make costly changes to its operations. If AMC is faced with additional duties of 25-

percent, AMC will not be able to pass on the cost to its customers due to contractual obligations and will 

be forced to absorb the cost. And as a direct result, the decrease in sales will not cover operational costs, 

and would force AMC [ ]. 

AMC’s windshield wiper motor rack and panel connector are products that are incorporated into [

] motor vehicles. [

 ]. The U.S. is a major market for [ ] 

vehicles. In 2017, [ ]. [
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

 ]. Notably, many of AMC’s competitors 

have established manufacturing bases in other countries that are not subject to Section 301 tariffs and are 

able to continue their manufacturing at internationally competitive rates. This means that AMC would be 

less competitive, and AMC would have to absorb the material cost.

A 25-percent tariff increase on this product will harm all downstream businesses, which include 

U.S. businesses, auto manufacturers, distributors, and dealers across the U.S who use our products. These 

tariffs will result in direct employee layoffs and place pressure on indirect employment as well. Our 

employment of over 900 Americans in Kentucky, Ohio, Indiana, and Michigan would be put at risk if we 

could not supply these products to our automotive customers in the United States.

C. This product is not strategically important to “Made in China 2025” or other Chinese industrial 

programs.

AMC’s imported product requires the use of older and widely used technology that is not targeted 

by the “Made in China 2025” initiative. the Chinese government’s acts, policies and practices did not

deprive our Chinese facilities of the ability to set market-based terms in licensing and other technologyrelated negotiations nor did it undermine our control over our technology in China. Finally, there have 

been no attempts to steal our technology, in part because it is not the “cutting edge” technology that 

would be of interest to the Chinese government or to Chinese companies. We submit that the exclusion 

of this product will not help China’s attempts to become a global leader in the aerospace, rail way, 

machine tools, and technology. 

As a wholly owned subsidiary, the ownership of AMC rests solely with Mitsuba Corporation. The 

majority ownership of AMC ensures that there is no Chinese state ownership. Moreover, Mitsuba Electric 
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

(Dalian) Co. Ltd.’s facility in China has not, to our knowledge, experienced any pressure from China, the 

government or any other entity to transfer technology or trade secrets. The Chinese government has not 

employed any tactics, such as discretionary or discriminatory administrative approval processes, joint 

venture requirements, foreign equity limitations, procurements or other mechanisms to regulate or 

intervene in AMC’s operations in China. Further, China has not required or pressured AMC to transfer 

any technology or intellectual property to a Chinese company, nor did China use discriminatory licensing 

processes to transfer technologies from our company to China. 

Conclusion

While AMC supports the goal of eliminating China’s unfair acts, policies, and practices, 

additional duties on HTSUS 8536.69.4030 will disproportionately harm AMC’s ability to support U.S.-

based auto manufacturing, innovation, and jobs. In sum: 

(1) This product is available only from China and cannot be obtained from a third country. 

(2) Moving manufacturing facilities back to the United States is not economically feasible 

without causing the company serious loss and possible dissolution.

(3) The inclusion of these tariffs on this product will cause disproportionate economic harm to 

not only AMC, but to U.S. businesses and U.S. auto manufacturers and dealers. Additional 

tariffs on AMC products may cause job loss in the United States and will negatively affect 

all firms relying on AMC products in the automotive industry. 

(4) This product is not strategically important to the “Made in China 2025” initiative because 

it is not “cutting edge” technology and does not involve new technology in the field of 

automotive industry. 
Corporate Office (AMC) Novi Office (AMN) Michigan Plant (AMM) Indiana Plant (AMI) Bardstown Plant (AMB)

2945 Three Leaves Drive 41651 W. 11 Mile Rd. 2945 Three Leaves Drive 21600 Monroeville Rd. 901 Withrow Court 

Mt. Pleasant, MI 48858 Novi, MI 48375 Mt. Pleasant, MI 48858 Monroeville, IN 46773 Bardstown, KY 40004

Phone (989) 773-0377 Phone (248) 305-7660 Phone (989) 773-0377 Phone (260) 623-3700 Phone (502) 348-3100

Fax (989) 773-1105 Fax (248) 305-7699 Fax (989) 773-1105 Fax (260) 623-3773 Fax (502) 348-3204

(5) The exclusion of these tariffs on this product will not interfere with the intellectual 

property rights of U.S. companies or result in theft of U.S. companies’ trade secrets.

We respectfully request USTR to exclude the windshield wiper motor rack and panel connector 

specifically:

8536.69.4030 Motor Vehicle Windshield Wiper Motor Insulated wire 

harness that works the joint between the vehicle side wire 

harness and motor side coupler.

.

from the additional Section 301 tariffs.

The submitter certifies that the information provided is complete and correct to the best of his

knowledge.

Sincerely,

David Martin Stevens

Senior Vice President

American Mitsuba Corporation