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 Document 

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

This tariff line applies to printed circuit connectors for a voltage not exceeding 1,000 V. Specific items 

imported by LNCA are connectors used to transmit audio/video signals, and in PC applications. Some of 

these devices change the connector type or gender, making for easier adaptation to customer 

requirements. Additional items that LNCA anticipates importing under this tariff line include simplex 

and duplex fiber adapters, in various colors and connector combinations, that allow for coupling of fiber 

assemblies under a wide range of applications and conditions. These adapters were classified in a 

different 10-digit category in prior years. The 2015-2017 quantity and value data presented in this 

application cover the full range of items for which LNCA is today requesting an exclusion. 

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/ 

8536694040 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Rochford, Susan 

Legrand North & Central America (LNCA) 

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

Requestor Representative: John Magnus / TradeWins LLC 

5. Requestor's relationship to the product: Importer 

6. Does this submission in regulations.govinclude additional attachments? 

NO 

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. 

N/A 

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

NO n 

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

YES 

•-• 

NI 

...--I 

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: BCI 2017 Quantity: BCI 

2016 Value: BCI 2016 Quantity: BCI 

2015 Value: BCI 2015 Quantity: BCI 

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). 

Background on LNCA: The Legrand Group has had a presence in the United States since 1986 and 

today has operations in 41 U.S. states. We design and manufacture products and solutions that 

deliver and control power, light and data in commercial, industrial and residential buildings. Our 

products include switches, outlets, cable management solutions, electrical ground boxes and 

raceways, racks and cabinets for data centers, mounts for AV equipment, lighting and plugload 

control systems, and energy-efficient lighting solutions. LNCA sources wherever possible from 

U.S.-based suppliers, but also depends on imports from China which are a mix of (1) electrical and 

electronic components that are not adequately available in the United States, and (2) finished 

products manufactured at Legrand-owned facilities in China. 

Products covered by exclusion request: 8536.69.40.40 is the 10-digit statistical breakout for printed 

circuit connectors within an 8-digit category (8536.69.40) that holds various types of "other" 

connectors for optical fibers, optical fiber bundles, or cables. These printed circuit connectors are 

commodity goods unconnected to the high-tech and IP-intensive sectors at the heart of the Section 

301 proceeding and of the USTR's findings regarding Chinese government acts, policies and 

practices. These connectors are components in the various power, light and data solutions that 

LNCA, through a U.S. workforce, designs and deploys in the United States. Taxing the physical 

components of these power/light/data solutions makes energy efficiency more expensive, safety 

more expensive, data management more expensive, and building construction more expensive. 

Other reasons why an exclusion is appropriate: (1) There is no realistic chance that U.S. production 

will replace commodity printed circuit connector production that leaves China because of the 

Section 301 tariffs. (2) Continuing to apply tariffs on this 10-digit category holds little "leverage" 

value or potential to motivate the Chinese government toward policy reform. (3) An exclusion 

would not undermine List 1's overall trade coverage, as total U.S. imports from China in this 10-digit 

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