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 particular product of concern:

4.

*

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/

7.

5. Requestor's relationship to the product:

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.

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1

Public Document

Proposed for exclusion from Section 301 tariffs for HTSUS subheading 8422.30.9191 are two 

aluminum machines to assist with softgel preparation and encapsulation, including a gelatin 

melter, a gelatin service tank, and a drying tray. The two aluminum machines' finished 

dimensions and weight are as follows: (1) 2040mm (L) x 960mm (W) x 1900mm (H), 1,500 Kgs 

("Large Machine"); and (2) 1440mm (L) x 660mm (W) x 1350 mm (H) ("Small Machine"), 400 

Kgs.

The Large Machine is intended to be used to prepare softgel capsules that will be sold by us. 

The Small Machine is intended to be used exclusively for research and development of 

potential future types of softgel capsules. 8422.30.9191 Gulati, Ved Orochem Technologies, Inc. Ram Natarajan, Natarajan Worstell LLC Purchaser YES Public Document
8. Is this product, or a comparable product, available from sources in the United States? (If you

9. Is this product, or a comparable product, available from sources in third countries? (If you

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.

2017 Value:

2016 Value:

2015 Value:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?

YES YES $0.00 0

$0.00 0

$0.00 0

FINAL PRODUCT 0.0
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).

Orochem Technologies, Inc. started as a biotech and chromatography company to 

manufacture unique sample prep technology products for the bioanalysis, drug discovery, and 

the genomics and proteomics markets. Over the years, we have added a purification line of 

business, including such products as natural oils (e.g., fish oils, vitamin D purification, etc.). 

We hold process patents regarding the purification methodologies used by us for the work 

noted above. We are now (in 2018) moving to the next stage of this process, which is creating 

vegetarian-based softgel capsules to hold the purified products we specialize in. We were 

established in 1996, and currently employ 25 individuals at our headquarters in the suburbs of 

Chicago, Illinois. 

The manufacturers of the Large Machine and Small Machine have custom-designed said 

machines to run using vegetarian starch. Said vegetarian starch is manufuactured by a 

specific Chinese vendor from whom we purchase said starch. The machines will prepare 

vegetarian (kosher certified) softgel capsules that we intend to sell. The machine 

manufacturers have guaranteed that the relevant equipment will work with the above-noted raw 

materials, so it was appropriate to purchase said custom-designed equipment from the 

Chinese manufacturer.

Further, softgel encapsulation equipment manufactured in the USA, Korea, and India are 

cost-prohibitive, making it impossible for us to be a viable entity in the softgel capsule space. 

As this is a new line of business for us beginning in 2018, it is imperative that we stay 

cost-effective.

In summary, purchasing the two pieces of aluminum equipment from non-Chinese sources was 

not a viable option, given the prohibitive cost disadvantages of the other countries noted 

above. Orochem Technologies, Inc. asserts that the Section 301 tariff on aluminum softgel 

encapsulation machines is unduly burdensome and prohibitive. Said tariffs put significant 

financial pressure upon us, and ultimately will lead to a greater pass-through cost to our future 

clients.

Orochem Technologies, Inc. respectfully requests that the aluminum softgel encapsulation 

machines (as described above) be excluded from the Section 301 tariffs for HTSUS 

subheading 8419.89.9585.
Orochem Technologies, Inc.

340 Shuman Boulevard

Naperville, IL 60563

info@orochem.com

www.orochem.com

Requested Exclusion for HTSUS Subheading 8422.30.9191: Machinery for filling, closing, 

sealing, capsuling or labeling bottles, cans, boxes or other containers; machinery for aerating 

beverages; nesoi

“Large Machine”
“Small Machine”