503515 

PUBLIC VERSION 

BUSINESS CONFIDENTIAL 

INFORMATION REDACTED 

BEFORE THE OFFICE OF THE UNITED STATE TRADE REPRESENTATIVE 

DOCKET NUMBER: USTR-2018-0025 

    

 Request for Exclusion of Particular Products from the Determination of Action Pursuant 

 to Section 301: China’s Acts, Policies and Practices Relating to Technology Transfer, 

 Intellectual Property and Innovation. 

 Submitted by: PTM Corporation 

      

 

 Leslie Alan Glick 

 Butzel Long PC 

 1909 K Street NW, Suite 500 

 Washington D.C. 20006 

 Tel: 202-454-2839 

 E-mail: Glick@Butzel.com 

 Counsel to PTM Corporation 

September 24, 2018 
2 

Exclusion Requests Section 301 List 1 Information Submitted by PTM Corporation 

 This request for exclusion is submitted by PTM Corporation in response to the Notice in 

the Federal Register 83 FR 32181 (June 20, 2018) titled Procedures to Consider 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, issued by the Office of the United States Trade Representative. 

 PTM Corporation (“PTM”) is a certified woman-owned small business and has been 

producing metal stampings since 1972. Its expertise and experience is wide ranging, to include 

detail part design, prototype and tool build and high-volume production. PTM has literally 

produced billions of metal stampings for its clients. From small clips and fasteners to car roofs 

and mower decks, they have done it all. PTM metal stampings are found on an estimated 70-

75% of all cars and light trucks on the road today. 

Section 301 Investigation: China's Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation - Form to Request Exclusion of Product 

1. Indicate whether the comment contains business confidential information (BCI), is a 

public document, or is a public version of a BCI document. 

BCI 

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

 The product of concern is a Machine Tool/Mechanical Stamping Press. Its weight is 

approximately 1,003,000 pounds of steel and motors. When fully erected, it is about 21 feet long 

by 9 feet wide by 29 feet high. This machine tool will be used to stamp precision parts and 

components for the end user. The supplier is JIER and the model description is 

S4-1000x6100x2450. Photos are attached. 

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 

 8462994030 

4. Requestor Information: 

 Requestor Name (Last, First): Burkhart, Renee

 Organization Name: PTM Corporation

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

 Requestor Representative: Leslie Glick, Butzel Long 
3 

5. Requestor's relationship to the product: 

 Purchaser 

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. 

 Contains BCI 

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

Yes, but not in the time frame and delivery requirements needed to meet customer’s 

needs for just-in-time deliveries. We were quoted a delivery lead time of two years. 

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

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: N/A 2017 Quantity: N/A 

2016 Value: N/A 2016 Quantity: N/A 

2015 Value: N/A 2015 Quantity: N/A 

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). 

 PTM Corporation explored the United States market to buy an unused large mechanical 

press that would meet the specifications and, more importantly, timing of the commissioning. 

The press needed to be fully operational within 12 months of purchase order. Due to PTM’s 

 
4 

PUBLIC VERSION 

BUSINESS CONFIDENTIAL 

INFORMATION REDACTED 

requirements, PTM could not find a domestic source to build a press within the time and 

specifications needed (see attachments A & B). 

 Upon looking elsewhere, PTM identified two companies that could possibly produce the 

press. One company was in Canada, and the other was JIER North America, with a sales and 

service center in Plymouth Michigan, near PTM. The press would be manufactured by their 

tooling division in China. The company in Canada could not produce the press to best meet the 

specifications that PTM needed, and they could not produce it to meet the timing required. 

However, the JIER press in China was able to meet all specifications and dimensions and 

committed to the timing that PTM required. PTM commissioned JIER North America to build 

the press in December of 2017 (see attachments C, D, & E). 

 The economic impact of a 25% tariff would have a devastating impact on PTM, which is 

a Certified Women Owned Small Business. The cost of the press is [ ], so the 25% 

tariff would be [ ]. This would be a severe hardship to PTM who, again, is a certified 

women-owned small business. Paying the tariff would delay the in-service date of the press 

because there would not be funds available to purchase the additional installation items needed to 

get the press fully functioning (see attachments F & G). Not commissioning this press within the 

current time line would be devastating to the growth and viability of PTM. Job creation would 

be limited (see attachment H). 

 PTM Corporation has been quoting and winning work for this press and is committed to 

the current timeline with our customers. Moreover, PTM, who is classified as a critical supplier 

with several U.S.-based automotive companies, has been commissioned to produce mass 

production parts for its customers (see attachment I). The tariff could create a non-build scenario 

and OEM production line shutdowns, making this an economic hardship in the automotive 

industry. 

 Furthermore, our supplier has alluded to cancelling the contract between PTM and JIER, 

due to the tariff, jeopardizing the installation of the equipment, resulting in huge losses in 

customers, funds, and reputation. 

 This press is not a high-technology item and is not subject to a patent. It is older 

technology, hence the shorter lead time. It should not be considered strategically important to 

the “Made in China 2025” program (see attachment J).

 

 Requestor Representative: Leslie Alan Glick 

 Butzel Long PC 

 1909 K Street NW, Suite 500 

 Washington D.C. 20006 

 Tel: 202-454-2839 

 E-mail: Glick@Butzel.com 

 Counsel to PTM Corporation 
September 19, 2018 

CERTIFICATION 

PTM CORPORATION 

6560 BETHUY ROAD 

FAIR HAVEN, Ml 48023 

WWW.PTMCORPORATION.COM 

PH. 586.725.2211 

I hereby certify that the information provided is complete and correct to the best of my knowledge 

9/19/18 

Renee Burkhart, CPA 

Director of Accounting 
PTfl 

CORP 

September 19, 2018 

PTM CORPORATION 

6560 BETHUY ROAD 

FAIR HAVEN, Ml 48023 

WWW.PTMCORPORATION.COM 

PH. 586.725.2211 

Certification in Connection with Request for Business 

Confidential Treatment 

I hereby certify that I have read the attached comments concerning the proposed modification of action 

pursuant to section 301 and request business confidential treatment for the information designated by 

brackets and certify t hat disclosure of this information would endanger trade secrets or profitability and 

that the information would not cust omarily be released to the public. 

Sincerely, 

Renee Burkhart, CPA 

Director of Accounting