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

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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 CNC 

Cutting and Sawing 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

CNC Cutting and Sawing Machines are factory equipment used in the manufacturing 

of couplings. Specifically, they cut steel pipes of various diameters. The blank tubes they

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

create are later refined into couplings. These 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.

These particular CNC Cutting and Sawing Machines are computer numerically 

controlled. The JQG-365 is used to cut steel pipe between 5.5" and 14.4" in diameter. The 

base machine is 13.8’ x 9.84’ x 10.5’, the feeding device is 8.2’ x 9.84’ x 11.16’, the 

electronic control system is 8.2’ x 3.28’ x 6.56’, the hydraulic system is 6.56’ x 4.92’ x 

4.92’, the bench device is 52.5’ x 16.41’ x 6.56’, and the imprinting device is 2.62’ x 2.62’ 

x 7.87’. The base machine weighs around 26 tons, while the rest of its parts collectively 

weigh around 45 tons. The GZK4232 is used to cut steel pipe up to 11.8” in diameter. It is 

7.55’ x 5.91’ x 4.59’. The GZK4240 is used to steel pipe up to 15.7” in diameter. As new, 

numerically controlled sawing or cutting-off machines, all three pieces of equipment fall 

under HTSUS subheading 8461.50.4050.

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 

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 
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 3

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 one GZK4232, one GZK4240, and one JQG-365.

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 CNC Pipe Cutting and 

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

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

particular products would cause severe economic harm

First, these CNC Pipe Cutting and Sawing Machines are only available in China. 

Although other similar equipment exist for sale in third-countries, those are incompatible 

 

2

See Attachment 3.
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 4

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 CNC Pipe Cutting and Sawing 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 saws 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 three 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 

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 
LAW OFFICE OF 

JEFFREY M. WINTON PLLC

U.S. Trade Representative

October 9, 2018

Page 5

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 GZK4232, GZK4240, and JQG-365 pipe cutting and sawing 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. GZK4232 CNC Band Sawing Machine Image

2. GZK4240 CNC Band Sawing Machine Images

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

4. Factory Blueprint Showing Location of Pipe Sawing and Cutting Machines
Attachment 1 

GZK4232 CNC Band Sawing Machine Image

Attachment 2

GZK4240 CNC Band Sawing Machine Images

Attachment 3

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
Attachment 4

Factory Blueprint Showing Location of Pipe Sawing and Cutting Machines