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 Document

These water pumps are used in ornamental ponds/fountains only, and are not used in any industrial 

applications. These pumps are used to move water only to circulate the flow within the pond and create 

visually aesthetic features. There are no commercial applications for these pumps, it is simply for 

household use, and residential property improvement. The pumps range from 100 GPH to 8000 GPH. 

These pumps are variable frequency asynchronous magnetic driven pumps, the benefit of this technology 

is very low power consumption, which is not available in the other pump designs. For example, pumping 

3600GPH with consumption of only 160 watts.

22EV125 EVO II EV700 PUMP 700GPH

22EV155 EVO II EV900 PUMP 900GPH

22EV175 EVO II EV1200 PUMP 1200GPH

22EV175.S EVO II EV1200 PUMP 1200GPH

22EV200 EVO II EV1800 PUMP 1800GPH

22EV225 EVO II EV2400 PUMP 2400GPH

22EV250 EVO II EV3000 PUMP 3000GPH

22EV275 EVO II EV3600 PUMP 3600GPH

22EV275.S EVO II EV3600 PUMP 3600GPH

22PD041 EP700 Filtration/Waterfall pump

22PD042 EP1100 Filtration/Waterfall pump

22PD043 EP1700 Filtration/ Water pump

22PD044 EP 2300 Filtration/ Waterfall pump

22PD045 EP2900 Filtration/ Waterfall pump

22PD046 EP3500 Filtration/ Waterfall pump

22PV030 MAG DRIVE PV250 PUMP 250GPH

22PV050 MAG DRIVE PV350 PUMP 350GPH

22PV075 MAG DRIVE PV550 PUMP 550GPH

22PS560 PONDMAX PM150SP Solar Pump Kit

22PS565 PONDMAX PM350SP Solar Pump Kit

31SP350 PondMAX PM150SP Solar Pump (Pump Only)

31SP351 PondMAX PM350SP Solar Pump (Pump Only)

8413.81.0040 Matthew Holt CMT Group LLC Matthew HoltImporter NON/A
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 48060.38 1254 173406.98 6404

These water pumps are used in ornamental ponds/fountains only, and are not used in any industrial 

applications. These pumps are used to move water only to circulate the flow within the pond and 

create visually aesthetic features. There are no commercial applications for these pumps, it is simply 

for household use, and residential property improvement. These pumps are asynchronous magnetic 

driven pumps, which are not available from any manufactures in the United States. Our 

manufacturing partner in China has been successful in developing pumps that are more energy 

efficient and technologically advanced then any other pump manufacturer in our industry. 

If tariffs continue to be enforced, this will cause consumers to pay more for the initial investment and 

higher continued expenses for power consumption. This creates two problems. First as electronics 

continue to dominate our lives, energy efficiency needs to be an important political agenda and tariff 

such as this is neglecting acknowledge that. Second problem is as costs rise above the average 

consumer discretionary income, our industry will suffer and many companies like ourselves will have 

to close. This will cause higher unemployment and slow economic growth similar to what already 

happened in the previous financial crisis. 

 

We recommend creating an additional sub category of pumps for ornamental water features and 

aquariums where by you can exclude all products used strictly in these applications from tariffs. This 

is supported with the fact that there are no manufacturers in the United States that producing these 

products.