Each switch occupies a 2”x2’x2” space when coiled up.

Il. About GE Appliances

GE Appliances (GEA) has manufactured major appliances in the United States for over a
century, first as a division of GE Company, and now, since the June 2016 acquisition, a Haier
company. We employ over 12,000 associates in the U.S., 9600 at in manufacturing-related
positions at plants in Louisville, Kentucky, Decatur, Alabama, Lafayette, Georgia. Selmer,
Tennessee and Camden, South Carolina. The remaining 2,500 are in sales, distribution and
other support functions. The company manufactures clothes washers and dryers,
refrigerators, cooktops, ovens, ranges and packaged terminal air conditioners for commercial
applications.

In addition to the 12,000 direct jobs, of GEA’s economic impact has resulted in creation of an
additional 30,000 jobs as a result of our investment in product development, manufacturing
machinery and equipment, purchased goods and services, and the salaries and benefits
earned by our employees. All told, GEA’s operations contribute $8.8 billion annually to national
GDP.!

Beginning in 2011, GEA set on a course significantly to increase the percentage of its
appliances manufactured in the U.S. by on-shoring manufacture of new products. New models
of refrigerators, clothes washers, dishwashers, water heaters, ovens and commercial air

1 Source: Capital Policy Analytics, based on 2016 IMPLAN Economic Modeling System, October 2018. Authors:
Russell Kashian, Ph.D., Ike Brannon, Ph.D., Capital Policy Analytics, October 2018. All numbers are based on
2017.


Attachment 1a
Attachment 1b

Attachment 1c

NOT SUSCEPTIBLE TO PUBLIC SUMMARIZATION


I. Description of the Product of Concern

The rotary switches for which GEA seeks exclusion are assemblies comprised of 1 to 6
switches tied to a wire harness connected to a printed circuit board (PCB) with an embedded
copper ring, each part of which has a different resistance. As the rotor is turned a pin contacts
different resistances sending a signal to start one of the functions available on the dishwasher,
clothes washer or cooking appliance.

As consumers have demanded more product features to improve utility, flexibility and make
their lives easier, rotary switches have played an important role in increasing the variety of
options to interact with appliances operated by control knobs. By increasing the variety of
operating modes rotary switches allow consumers to choose which wash cycle is best for a
load of dishes, the types and size of clothes washer loads and temperatures and facilitate the
various cooking product uses.

A picture of the rotary switch assembly is attached below as Figure 1.



conditioners were introduced during the following seven years. And, the degree of vertical
integration also accelerated.

In part, investment dollars were able to be redeployed to on-shoring and vertical integration by
cost-savings made possible by sourcing low-value, low-cost components from the global
supply chain, much of it located in China. That redeployment in turn has also fueled job
creation and promoted up-skilling of the workforce now focused on advanced manufacturing
tasks.

Ill. Rationale for the Exclusion Request

Several of the on-shored products use the rotary switches covered by this petition: the
dishwasher plant and laundry plant in Louisville, KY and the cooking products manufacturing
operation of our Roper Corporation subsidiary in Lafayette, GA. On Oct. 1, GEA announced a
$200 million investment in the Louisville dishwasher and laundry plants that would add 400
jobs. These plans, which took about 2 years to create, were finalized before the tariff on
rotary switches and other manufacturing inputs were proposed and announced even after the
implementation decision in the hope that alternative supplies could be timely found, other
remedial measures might be taken and/or that this administrative process created by USTR
would provide relief. Together the Louisville plants employ

A. The Product of Concern is Only Available from China

Rotary switches for use in the dishwashers, laundry and cooking products designed by GEA
engineers are not available from U.S. suppliers. Alternatives supplies have not been found.
As part of efforts to remediate the impact of the 25% tariff GEA sought quotes from other
suppliers. Not one chose to offer a quote. The three responses are attached hereto as
Attachments 1 a, b and c.

B. Imposing an Additional 25% Duty on The Product Will Cause Severe Economic
Harm to GE Appliances, its U.S. Employees and U.S. Consumers

The 25% tariff adds i per rotary switch. While this might seem to be a
manageable cost, the combined effect of that 25% on the several imported inputs used in the
manufacture of finished goods has a punishing impact on overall product cost that, for List 1
items alone, such as motors, pumps, ball bearings, stators & rotors, capacitors, resistors and
controls could well exceed per appliance, which, if passed along by resellers to
consumers could range from . Recent research on consumer sensitivity to price
changes found that price increases as low as 4-7% would result in a 3-point drop in industry

* https://www.nytimes.com/aponline/2018/10/01/us/ap-us-appliance-jobs-kentucky.html?partner=IFTTT
https://www.courier-journal.com/story/money/companies/2018/10/01/ge-appliances-adds-400-louisville-jobs-200-m-

investment/1457998002/



Company Certification of Confidential Business Information

GE Appliances ("GEA") is voluntarily providing this letter, the attached exhibits, and all other
information (collectively, the “submission”) concerning the product to the USTR. This
submission includes confidential, trade secret, commercial or financial information that GEA
would not customarily release to the public and disclosure of the information identified as
business confidential would endanger trade secrets or profitability and cause irreparable harm
to GEA. Pursuant to the USTR’s instructions in 83 Fed. Reg. 32183, business confidential
information is indicated by the use of brackets throughout this submission. GEA requests that
the USTR and its staff maintain the submission as confidential pursuant to all applicable laws
and regulations, including, without limitation, the Freedom of Information Act (“FOIA”). | certify
that | am authorized to make confidentiality claims of this sort on behalf of GEA.

Signature: Fe : :
[
Name: Earl F. Jones &__)

Date: October 9, 2018



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.

Public Version of BCI

2. Please provide a complete and detailed description of the product of concern:

See Attachment |

3. 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/

8536509025

4. Requestor Information

Requestor Name (Last, First): [Jones, Earl ]

Organization Name: [GE Appliances, a Haier compam ]

Note: Representatives submitting on behalf of an organization must enter information below.

Requestor Representative: [ ]

5. Requestor's relationship to the product: [importer |

6. Does this submission in regulations.gov include additional attachments?

YES

7. Please indicate whether any additional attachment contains business confidential
information (BCI), is a public document, or is a public version of a BCI document.

Public Version of BCI

VERSION 1 CONTINUED BELOW


shipments. As noted above, since only U.S. appliance producers would need to implement
cost-recovering price increases, they would feel the full brunt of the share losses, which would
reach double-digit levels.

This exclusion petition process offers the [J employees who manufacture GEA products
using rotary switches and these other inputs the relief from the uncertainty that potential lost
sales would mean to the security of their employment.

C. The Products Are Not Strategically Important or Related the “Made in China
2025” Industrial Program

The mature nature of the technology of these products cannot advance the China 2025
industrial policy that the tariffs seek to challenge. And the critical role they play in sustaining
U.S. manufacturing, in keeping our U.S.-manufactured products competitive with foreign
exporters of finished refrigerators are additional reasons the Government should exclude these
water filters from tariffs under Section 301.

Moreover, granting this exclusion request will not undermine List 1 product coverage. Total
US imports from China in the pertinent 8-digit tariff code category during 2017 were valued at
~$486,317,000.00. In the alternative, should USTR elect not to exclude the entire 10-digit
category but only Switches, Rotary, Rated At Over 5 A, used to interpret electrical resistance
into household appliance cycle selection.

D. US Customs and Border Protection Agents Can Capably Administer This
Exclusion Request with Minimal Administrative Burden

HTSUS 8536.50.9025 covers rotary switches for many applications. Given the modest impact
excluding the entire HTSUS code, complete exclusion might be easier for Customs and Border
Protection agents to enforce.

IV. Conclusion

For these reasons, GEA respectfully requests that USTR grant this request and exclude the
Product of Concern from the additional ad valorem duty of 25%. Thank you for consideration of
this request.

Respectfully


8. Is this product, or a comparable product, available from sources in the United States?:

INO.

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

INO

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: Business Confidential 2017 Quantity: Business Confidential
2016 Value: Business Confidential 2016 Quantity: Business Confidential
2015 Value: Business Confidential 2015 Quantity: Business Confidential

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).

See Attachment 1

VERSION 1 END



GE APPLIANCES
a Haier company

Public Business Confidential Information

Attachment 1

October 9, 2018
VIA Federal eRulemaking Portal

Hon. Robert E. Lighthizer

United States Trade Representative
600 17th St. NW

Washington, DC 20508

Attn: William L. Busis, Chair, Section 301 Committee

RE: Requests for Exclusion of Particular Products from the Determination of Action
Pursuant to Section 301: China’s Acts, Policies, and Practices Related to
Technology Transfer, Intellectual Property, and Innovation,

Docket No. USTR-2018-0025

Dear Ambassador Lighthizer:

GE Appliances, a Haier company, (“GEA”) respectfully submits this request for an exclusion
from the Section 301 tariffs on the following product described herein and listed in Annex B of
the USTR’s June 30, 2018 notice. 83 Fed. Reg. 28710:

Switches, Rotary, Rated At Over 5 A, For A Voltage Not Exceeding 1,000 V. This
product is classified under 8536.50.9025 HTSUS. The group of rotary switches covered by
the petition are for Use in Household Appliances.

These rotary switches can be installed in a dishwasher to select the desired cycle, in a clothes
washer to select wash water temperature or clothes care cycle and in an oven range or
cooktop to enable ignition. They are manufactured by [ake eC aE of China.
In support of this request for exclusion of the Product of Concern from the Section 301
additional tariffs, GE Appliances states further as follows: