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: Combustion System - Liners

Submitted by: Chrissy Borskey, GE Power

GE Power is a world leader in power generation, transmission, and distribution 

solutions. Its revenues reached $36 billion in 2017, making GE Power one of the world’s 

largest energy and engineering businesses. GE Power plants generate one-third of the 

world’s electricity, and its power generation equipment is present in over 140 

countries. GE Power is actively involved in all facets of the global energy sector; it designs 

and manufactures industry-leading gas and steam turbines, reciprocating engines, 

gasification systems, and nuclear power generation technologies. GE Power also provides 

transmission and distribution technologies that enable utilities and grid operators to 

efficiently manage electricity, and is actively engaged in providing industry-leading 

solutions in energy storage and microgrids. GE Power employs 14,600 people in the United 

States, and has 23 primary U.S. manufacturing facilities, with additional service and repairs 

shops in various locations across the country. GE Power exported [BCI] worth of goods and 

services from the United States in 2017.

Although GE Power has operations and facilities around the world, the United States 

remains the center of much of its manufacturing, with key facilities, including for some of 

the company’s most advanced power turbines, in South Carolina, North Carolina, New York, 

and Maine, supported by parts and component manufacturing facilities across the 

country. GE Power’s impact on the U.S. economy is amplified by its purchases from 8,300 

U.S. suppliers. Although the majority of GE Power’s parts purchases for its U.S.-made gas 

power equipment comes from U.S. suppliers, GE Power also purchases some parts 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 rivals, and to deliver a 

world-class product at a competitive price to U.S. and global power companies. Access to 

competitive foreign inputs strengthens the competitiveness of GE Power’s operations in the 

United States and generates opportunity for our workers and U.S. suppliers. 

The parts and components that GE Power imports from China for use in U.S.-made power 

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. Approximately [BCI] of the 818 tariff lines on the July 6 list (“List 1”) affect goods that GE 

Power imports from China, many covering multiple products used in GE Power’s U.S. 

manufacturing. [BCI] 
Gas Turbines

GE Power’s land-based power generation gas turbines contain intellectual property, 

complex manufacturing processes & equipment, and requires specialized human resources 

to produce making such components extremely difficult and expensive to move outside of 

China within a two-year timeframe. Given the complexities of such components, GE Power 

previously entered long-term supply agreements with Chinese suppliers to ensure 

uninterrupted supply so that GE Power fulfills its customer obligations. In most cases, reallocating demand to alternate suppliers would put GE Power into breach of its contractual 

obligations and would face extensive legal penalties. 

A gas turbine has four main sections: the inlet, the compressor, the combustion system 

(combustor) and the turbine (and exhaust). The compressor draws air into the gas 

turbine engine, squeezes/pressurizes it, and feeds it to the combustion chamber at speeds 

of hundreds of miles per hour. Combustion is known as “burning.” Combustion in its 

simplest form is the basic chemical process when fuel is injected into the pressurized air 

from the compressor and releasing energy. The main purpose behind combustion is to 

create some sort of energy to produce the work. Essentially, it is the production of a 

certain amount of energy transferred by the force of heat and fire. The turbine is a 

complex arrangement of alternate stationary and rotating blades and shroud segments. As 

the hot combustion gas passes from the combustion system through the turbine is expands, 

as it passes through, it forces the turbine blades to spin. The rotating blades perform a dual 

function: they drive the compressor to draw more pressurized air into the combustion 

section, and they spin a generator to produce electricity.

Product Descriptions and Rationale

The combustion system of a gas power turbine contains many static precision 

components, several of which GE Power obtains from China, many designed to enable

such products to withstand operating temperatures exceeding the melting point of the 

base metals. 

Combustion System - Liners contain the primary combustion reaction. Combustion 

Liners are made of high-quality nickel-based alloy material and are cylinder in shape but 

contain a variety of dimensions. Combustion System Liners have unique and necessary 

designs and performance specifications developed by GE Power and contain proprietary 

company information, and are currently supplied to GE Power solely from China, so 

alternative sources outside China are not currently available. [BCI]
 

Should the Administration not grant a tariff exclusion for the Combustion System Liners, 

the impact of the tariffs on that product would cause severe economic harm to GE Power, to 

our customers, and to our U.S. workers and U.S. suppliers. U.S. leadership in the power 

equipment industry would be harmed, as the proposed tariffs would increase input costs 

for U.S.-made products by GE Power, the largest power equipment manufacturer based in 

the United States. This would give an unintended competitive advantage to power 

equipment made in Europe, Japan and the rest of Asia – much of which use similar Chinese 

parts and components as GE Power but complete their final assembly outside the United 

States and thus are not subject to U.S. Section 301 tariffs. This risk is particularly acute in 

an industry like power equipment that is currently facing global overcapacity and 

heightened price sensitivity, in which any cost increase would harm these high-paying 

manufacturing jobs. Finally, the ultimate cost of the tariff on this product would, either by 

leading to increased cost for power equipment or by potentially leading to contract 

uncertainty, disrupt power supply projections by U.S. utilities; the likeliest way to 

compensate for that would be increased power costs, driving up the cost of basic electricity 

for U.S. consumers, as well as businesses. 

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

enhance Chinese capabilities across many manufacturing sectors. One of those nine 

initiatives identifies specific sectoral priorities, and one those is “electric power 

equipment;” however, the primary focus in this area has been on clean coal technology, 

renewables, and advanced materials and innovative components that are beyond the 

scope of the well-established products that GE Power imports from China.