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 particular product of concern: 

Part number P79044. Zinc plated, stamped steel part made from a custom die owned by Carefree of 

Colorado. The dimension of each part is 4x2.5x0.125" and each part weighs about 0.3 pounds. The zinc 

plated, stamped steel part is used in motorized winch products. 

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/ 

8483509080 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Tanner Sammons 

Carefree of Colorado 

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

Requestor Representative: Jones Day 

5. Requestor's relationship to the product: U.S. Producer 

6. Does this submission in regulations.govinclude 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 Document 

VERSION 2 CONTINUED BELOW 1 
BUSINESS CONFIDENTAIL 

B. Is this product, or a comparable product, available from sources in the United States? (If you 

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

NO 

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

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

YES 

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: [ 2017 Quantity: [ ] 

2016 Value: 2016 Quantity: [ 

2015 Value: 2015 Quantity: [ 

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

the production of a final product or products? 

INPUT (- 

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

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

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

% 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 
12. Please provide information in support your request, taking account of the 

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). 

Block 12 (Information to Support Request) 

Carefree of Colorado ("Carefree") respectfully requests that the product that is the subject of this request 

be excluded from the additional 25 percent tariffs because: (i) there is lack of alternative sourcing options 

for the product outside of China; (ii) imposing duties on the product would cause severe economic harm 

to Carefree, and other U.S. interests; and (iii) the product is not a high-end technology product and is not 

strategically important or related to the "Made in China 2025" or other Chinese industrial programs. 

Granting an exclusion will allow Carefree to continue its efforts to identify alternative sourcing options 

outside of China without disrupting its current business operations. 

Background Information 

Carefree, founded in 1985 and based in Broomfield, Colorado, is a Tier 1 supplier to recreational vehicle 

(Rv-) original equipment manufacturers ("OEMS") and aftermarket customers throughout the United 

States, as well as worldwide. Carefree produces sunshade awnings and slideout awnings in its 

Broomfield, Colorado manufacturing facility and sources components for those awning products from 

China. Ninety percent of Carefree's revenue is generated by sales to U.S. companies, both OEM and 

aftermarket customers. Carefree employs over 380 employees in Broomfield, Colorado and Elkhart, 

Indiana, of which nearly 300 are hourly production and warehouse staff. Carefree's hourly staffing is 

based solely on the volume of business supported in the United States. 

The product in this exclusion request is a zinc plated, stamped steel part from a custom die owned by 

Carefree of Colorado. 

For the reasons discussed below, Carefree respectfully requests that the product be excluded from the 

additional 25 percent duties. This request is one of X requests being submitted by Carefree covering its 

different components for its sunshade and slideout awning products. 

Lack of Alternative Sourcing Options Outside of China 

The RV market is extremely competitive and price sensitive. Purchasing decisions by Carefree's OEM 

customers can come down to pennies. With rising labor and energy costs in the United States, Carefree 

previously was forced to look to other countries for lower cost labor to build components for RV 

awnings. Carefree ultimately chose China to source the components. There are currently no U.S. 

suppliers that can competitively manufacture the volume of the Product that Carefree demands and, 

therefore, Carefree responded "No" in Block 8 of the product exclusion form. Although there potentially 

are other suppliers outside of China for components for our RV awning products, including the Product, 

those suppliers cannot meet the quality standards demanded by Carefree's OEM and aftermarket 

customers as the components that Carefree sources from China are custom-designed to Carefree's 

requirements and necessitate high-cost tooling to produce. Carefree's Chinese suppliers have become 

valued partners and help ensure that Carefree is able to stay competitive in the OEM and aftermarket 

marketplace. Lower cost tooling, labor and material costs have been key factors in Carefree maintaining 

and growing market share in the U.S. economy. 

Due to the additional 25 percent tariffs, Carefree is actively pursuing new material sources outside of 

China, including the United States. The expediency at which the additional tariffs were imposed has 

handicapped Carefree's value to the marketplace and has not allowed Carefree to develop alternative 

siinnlier relations to keen onerations movino to meet customer demands New toolinp lead times alone 

VERSION 2 END 3