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

Transfer, Intellectual Property, and Innovation Form to Request Exchision 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 forrn, 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 product of concern: 

Spool Rod. Please see pan specification below. 

Length: 15.465 in 

Width: 0.500 in 

Peg Length: 0.125 in 

Peg Width: 0.250 in 

Material: Stainless Steel 

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/ 

8479909496 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Anway, Karl 

Reelcraft Industries 

Note: Representatives submitting on behalf of an organization rnust enter inforrnation below, 

Requestor Representative: 

5. Requestor's relationship to the product: 

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. 

Public Version of BCI 

VERSION 1 CONTINUED BELOW 

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

NO 

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

NO 

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: $281 2017 Quantity: 80 

2016 Value: $281 2016 Quantity: 80 

2015 Value: $421 2015 Quantity: 120 

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). 

1. This product is only available from the existing source in China, an American-owned company operating in 

China which sells to Asian markets while also trading parts with its sister company in the United States. The 

design for this product is specific to the individual Bill of Materials of reels manufactured in America. It is not 

mass produced or readily available, and is in fact only traded through intra-company sales. 

2. The imposition of additional duties on this product would cause severe economic harm to Reelcraft 

Industries. An increase in duties essentially amounts to an increase in costs, which will impact our employees, 

customers, and community. This reduces our ability to increase wages for American workers, as well as 

provide the outstanding benefits that allow them to prosper and grow within the local community, boosting 

the local economy, and help to keep America the prosperous nation it is today. 

The increase in costs risks the possibility of a reduction in workers, a reduction in workers pay and benefits, 

or an increase in prices which would prompt custorners to favor foreign competitors and become a loss for the 

American economy at large. 

3. This product is not related to "Made in China 2025" or other Chinese industrial programs to the best of our 

knowledge. This is a low-technology industrial component which represents no strategically important 

economic factor for our current trade relations. 

VERSION I END 2 
0 .500 ±.010 

LTR REVISION DESCRIPTION DATE E.C.N. 

Al REDRAWN TO CAD • 7-21-92 5009 

15.465 ±.015 

DRAWING TITLE 

MATERIAL 

STAINLESS ST' L 

302, 303 

FINISH 

NONE 

HEAT TREAT 

UNLESS OTHERWISE NOTED: 

DIMENSIONS ARE ,INCHES. ±2'C0NC..010T.I.R. 

FRACTIONS REF. TO IND. sms. 

REMOVE BURRS,BREAK SHARP 

CORNERS NOT TO EXCEED .015 

MACH.SURFACES ARE 

\//-3.25 MAX. -

DRAWN BY DB 7-21-92 

NEXT ASS 'Y 

ROD, SPOOL 

USED ON 

CHECKED BY NON E EXP.NO. 

ENG. APPROVAL 

WEIGHT P&IC CODE 

NO0 

MFG. APPROVAL 

SCALE 

CGD 

ADB 

1:1 A 

DRAWING NO. 

260381 

SIMILAR TO: