PUBLIC VERSION OF BCI

October 9, 2018

Addendum to Request for Exclusion from the Determination of Action Pursuant to Section 301

Product Exclusion Request for: X-ray Table

Submitted by: Orrin Marcella, GE Healthcare

GE Healthcare is a leading producer of complex, life-saving medical equipment such as MRI machines, CT 

scanners, X-rays, and ultrasounds, with revenues of $19.1 billion in 2017. GE medical equipment is 

designed, produced, marketed and sold in the United States with the support of over 19,000 GE 

employees located throughout all 50 states, including at 24 U.S. facilities in Wisconsin, South Carolina, 

Utah, Arizona, Ohio, Massachusetts, New York, Washington, Indiana, and other states. GE Healthcare 

also supports thousands of additional workers who are employed by the 6,200 U.S. supplier companies 

that provide parts and services for GE medical equipment. GE medical equipment can be found in more 

than 6,000 hospitals across the United States. In addition, [BCI] of GE Healthcare’s global revenues 

comes from outside the United States. For example, GE Healthcare exports medical equipment worth 

nearly [BCI] from its facilities in Wisconsin alone, supporting 4,000 U.S. jobs, based on estimates by the 

Department of Commerce. 

While GE Healthcare has facilities around the world, the center of its manufacturing is in the United 

States, with large plants manufacturing finished products, including GE Healthcare most advanced 

medical equipment, in Wisconsin, South Carolina, and Utah. Those are supported by multiple GE 

Healthcare manufacturing facilities for parts and components elsewhere in the United States. As for 

externally sourced content, [BCI] percent of GE Healthcare’s externally sourced content used in its U.S. 

facilities comes from U.S. suppliers. GE Healthcare also purchases from competitive foreign suppliers in 

order to access inputs that may not be readily available in the United States, to maintain 

competitiveness with our global competitors, and to deliver a world-class product at a competitive price 

to U.S. and global health institutions. Access to competitive foreign inputs strengthens the 

competitiveness of GE Healthcare’s operations in the United States, which generates opportunity for our 

U.S. workers and U.S. suppliers.

The parts and components that GE Healthcare imports from China for use on U.S. made health 

equipment, although limited as a percentage of the machines’ content, are significantly impacted by the 

Section 301 tariffs on Chinese goods that took effect on July 6. Over [BCI] tariff lines of the 818 eightdigit tariff lines for which Section 301 tariffs took effect on July 6 list (“List 1”) affect products that GE 

Healthcare imports from China. Many of those tariff lines include multiple affected products for GE 

Healthcare. [BCI.] The ability to rapidly switch to new suppliers for parts used in medical equipment is 

further complicated because sourcing for medical devices sold in the United States is subject to 

oversight by the U.S. Food and Drug Administration, which has the authority to penalize or shut down 

manufacturers for failing to meet regulatory requirements. 

Product Description and Rationale

The X-ray table is used to hold and position the patient for an X-ray, as part of a radiography platform. 

The TABLE contains the control system that moves the table, and is used to hold the Digital Flat Panel 
Detector (a separate product in an integrated X-ray system) in a fixed position. The table’s main 

components are the mechanical systems to hold and position the patient, electro-mechanical systems 

control the table elevation, the power control systems for the Digital Detector, and Detection Grids. The 

X-ray table serves as the X-ray table for all X-ray systems that GE Healthcare sells in the United States. 

The X-ray table is shipped to GE Healthcare’s facility in Waukesha WI where it is integrated with other 

subassemblies to form an integrated radiography (X-ray) system.

The X-ray table contains proprietary GE Healthcare technology that enhances performance and allows 

the table to be integrated with other sub-assemblies of a GE Healthcare X-ray system. This product or a 

comparable product is not available from sources in the United States or in third countries. [BCI.]

[BCI.] Tariffs on the X-ray table would negatively impact GE Healthcare in the U.S. and our U.S. suppliers. 

U.S. leadership in the medical imaging equipment industry would be harmed as the proposed tariffs 

would increase input costs for GE Healthcare’s U.S. plants and provide a competitive edge, including in 

the U.S. market, to medical equipment made in Europe, Japan and the rest of Asia – much of which use 

similar Chinese parts and components as GE Healthcare but complete their final assembly outside the 

United States, and thus are not subject to the Section 301 tariffs. Decreased competitiveness of U.S.-

made medical equipment would also have a negative impact on U.S. jobs, at both at GE Healthcare and 

its 6,200 U.S. supplier companies. Resource-constrained health care providers would be hard-pressed to 

pay the added cost of 25% tariffs, and the cost of the tariffs on medical equipment could ultimately end 

up being born by U.S. health care consumers, or result in denying American patients access to U.S. made 

medical equipment.

The “Made in China 2025” initiative involves a broad range of cross-cutting initiatives to enhance 

Chinese capabilities across many manufacturing sectors. Although “bio-pharmaceuticals and highperformance medical devices” is one of the broad categories included in a list of industrial priorities, 

much of the focus in the area has been on bio-pharmaceuticals and innovative technologies, and not on 

the well-established products that GE Healthcare imports from China.