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September 11, 2018 

VIA ELECTRONIC FILING SUPPLEMENTAL NARRATIVE 

The Honorable Robert E. Lighthizer Docket. No.: USTR-2018-0025 

United States Trade Representative 

Office of the United States Trade Representative 

600 17th St. NW 

Washington, DC 20508 

Re: Bridgestone Industrial Products America’s Request for Exclusion from 

Section 301 Tariffs of Rubber Track 

Dear Ambassador Lighthizer: 

 

On behalf of our client, Bridgestone Industrial Products America (“Bridgestone Industrial”), we 

hereby submit our requests to exclude rubber tracks from the tariffs enacted against products 

from the People’s Republic of China (“China”), pursuant to Section 301 of the Trade Act of 

1974 (19 U.S.C. § 2411). These products are not economically and commercially available 

outside of China; none of them are high-tech products that are benefiting from the “Made in 

China 2025” program; and the imposition of additional duties on these products would 

significantly undermine Bridgestone Industrial’s competitive advantage in both the U.S. and 

global market, while having no beneficial impact upon any U.S. entity. 

For these reasons, Bridgestone Industrial respectfully requests that rubber track products 

imported from China, classified under 8431.49.9095 HTSUS, be excluded from the Section 301 

tariff list. 

I. Background 

Founded in 1931, Bridgestone has grown to become one of the largest tire and rubber products 

companies in the world. Through its various subsidiary companies, Bridgestone Corporation 

operates 50 production facilities and employs 55,000 workers throughout the Americas. 

Bridgestone Industrial, a wholly-owned subsidiary of Bridgestone Corporation, sells, distributes, 

and provides technical support for rubber tracks, rubber pads, and conveyer belts used primarily 

in the mining, construction and agriculture sectors. In the Americas, the company maintains 

offices in Nashville, TN, Barrington, IL and Santiago Chile. 

Operating in a global market, Bridgestone Industrial imports rubber tracks from Shenyang 

Bridgestone Co., Ltd, located in China. These rubber tracks are installed on vehicles forming the 

backbone of the construction, mining and agricultural industries. Bridgestone engineers 

pioneered the rubber track industry in the 1960s, and the company continues to utilize extensive 

research & development to produce the highest quality rubber tracks in the global market. 
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Bridgestone Industrial is committed to ensuring the continued success and growth of these 

industries, including the company’s own U.S. work force. The additional 25% duties on 

imported rubber tracks would cause severe economic harm to these industries in the form of 

unnecessary, increased costs. 

II. Exclusion Is Requested for the Increase Demand in the OEM and Aftermarket, and 

the Lack of Availability and Interchangeability Outside of Shenyang Bridgestone 

Bridgestone Industrial’s decision to import rubber tracks from China is driven by increased 

customer demand in the U.S. and global markets. The imported input products are then used to 

manufacture small earth moving equipment to original equipment and aftermarket customers. 

Bridgestone and its subsidiary companies develop raw materials such as natural rubber, synthetic 

rubber, carbon, and steel cord, which is all essential for the production of rubber tracks. This 

control over the fundamental components of a rubber track ensures product quality that is 

unequivocally superior to other manufacturers of rubber tracks. 

That supplier of rubber tracks, Shenyang Bridgestone, is a Bridgestone Corporation whollyowned facility in China. That subsidiary received no investment from the government or a stateowned enterprise (SOE). In addition, our wholly-owned facility has not benefited from the 

Chinese Government’s acts, policies or practices identified by the USTR as being unreasonable 

or discriminatory. To the contrary, the Chinese supplier does not burden nor restrict U.S. 

commerce. Shenyang Bridgestone increases U.S. commerce by complementing the U.S. 

operations and allows Bridgestone Industrial to offer high quality products to its U.S. and global 

customers. Furthermore, imports from affiliated company in China allow Bridgestone Industrial 

to compete in a global market, to invest saved capital in the U.S., and to create more 

management and administrative jobs in the U.S. 

To the best of its knowledge, Bridgestone Industrial cannot readily source the same or 

comparable products elsewhere in a commercially sufficient and cost-efficient manner, nor can 

the company increase its capacity quickly enough to meet the increased demand of its customers. 

Other suppliers of rubber tracks exist in China, Thailand, and Sri Lanka; however, the quality of 

their products is nowhere near comparable to Bridgestone’s rubber tracks. Without the Shenyang 

facility, Bridgestone Industrial would not be able to provide the sufficient quantity and quality 

demanded by U.S. customers. Simply put, the 25% ad valorem tariff on Bridgestone’s rubber 

tracks will threaten the supply of U.S. manufactured small earth moving equipment. 

III. Imposition of Ad Valorem Section 301 Tariffs Will Cause Severe Economic Harm to 

Bridgestone Industrial 

The additional 25% duties on Bridgestone Industrial’s imported rubber tracks will significantly 

increase its distribution cost. Because the company operates in a global market, the increased 

input cost would result in foreign competitors having a significant competitive advantage over 

Bridgestone Industrial because they will still be able to procure the same inputs from other 

countries without the 25% additional duty cost. The increase in the cost of input goods will also 

greatly raise the price of small earth moving equipment, resulting in a significant disruption to 
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users of such equipment in the mining, construction and agricultural industries. Bridgestone 

Industrial will be significantly less competitive in the U.S. and global market; thus, directly 

impacting our ability to compete with foreign producers. As a result, Bridgestone Industrial 

could be forced to lay off American workers due to the lost sales and increased competition from 

foreign companies. 

As discussed above, imported products from an affiliate in China enable Bridgestone Industrial 

to supply a full-range of rubber tracks desired by its customers. The increased operating costs 

due to the tariffs will undermine the company’s ability to offer customers rubber tracks in the 

original equipment market and aftermarket for the small earth moving equipment, which will 

result in lost sales. Because Bridgestone Corporation controls the U.S. and Chinese 

manufacturing facilities, imposing tariffs on the affiliated Chinese subsidiary company will also 

increase administrative costs designed for a multinational supply chain, possibly resulting in a 

reduction of U.S. jobs. 

IV. Rubber Tracks Are Not Related to “Made in China 2025” Initiative and Do Not 

Infringe on U.S. IP Laws and Regulations 

Shenyang Bridgestone is not a high-tech producer identified in USTR’s report, nor do the 

products it manufactures infringe on U.S. IP laws and regulations. The imported products do not 

benefit from the “Made in China 2025” initiative, or any of the other Chinese Government’s acts, 

policies or practices identified by USTR. 

In addition, force-transfer of technology only exists in joint-ventures between a U.S. and a 

Chinese company. However, Shenyang Bridgestone is a wholly-owned subsidiary of Bridgestone 

Corporation located in Japan. As mentioned above, Bridgestone Corporation wholly-owns both 

Shenyang Bridgestone and Bridgestone Industrial Products. Unlike joint-ventures, manufacturing 

subsidiaries do not result in the forced sharing of technology. Therefore, direct ownership of 

non-U.S. suppliers, such as Shenyang Bridgestone, increases U.S. commerce and should be 

promoted as a matter of U.S. policy. The imposition of 25% duties on Bridgestone Industrial’s 

imported products, however, will only punish the company, with no practical effect to eliminate 

China’s trade policies identified by USTR. 

V. Conclusion 

Based on the reasons stated above, we respectfully request an exclusion of the rubber track 

products identified in the accompanying exclusion requests from the Section 301 tariffs. The 

tariffs on Bridgestone Industrial’s products will significantly increase operating costs and make 

the company less competitive. The imported products are essential to Bridgestone Industrial’s 

core business, and none of the products are affected by the concerns cited by the USTR as 

justification for implementing the Section 301 tariffs. Tariffs on products that are not 

economically and commercially available to Bridgestone Industrial from U.S. producers will not 

advance national trade objectives and will be to the detriment of U.S. manufacturing.

 

****** 
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We request certain quantity and value information contained in the exclusion form be 

afforded business confidential treatment. The disclosure of which would cause severe 

economic harm to Bridgestone Industrial Products America’s competitiveness, and the 

information is not otherwise available to the public. However, the supplemental narrative 

does not contain proprietary information and could thus be released as a public document. 

Respectfully Submitted 

Daniel Cannistra 

Counsel for Bridgestone Industrial 

Products 
ATTACHMENT 

 
Part No. 561 and 511 

 
Part No. 513 

 
Part No. 531 

Part No. 579 
Part No. 687