Organization Name:

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

Requestor Representative:

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.

3.

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

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential

information (BCI), is a public document, or is a public version of a BCI document.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

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

VERSION 1

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).

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

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:
October 4, 2018 

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

600 17th Street NW 

Washington, DC 20508 

Re: Request for Exclusion of Certain Oil Well Beam Pumping Units with Exclusively AboveGround Structural Components from the Determination of Action Pursuant to Section 301 

Dear Ambassador Lighthizer: 

Liberty Lift Solutions, LLC ("Liberty Lift") respectfully submits this request to exclude certain oil well beam 

pumping units with solely above-ground structural components from the determination of action pursuant to 

Section 301 of the Trade Act of 1974. We respectfully request that certain information in this submission, which 

is identified by brackets, be afforded business confidential treatment. Disclosure of the business confidential 

information identified in brackets below would endanger the economic stability of Liberty Lift and would not 

customarily be released to the public. I certify that the information provided herein is true and correct to the best 

of my knowledge. 

Background concerning Liberty Lift. 

Liberty Lift is a small company started in 2012 and located in Houston, Texas providing a variety of pumps, 

related equipment and servicing to the oil and gas industry. The company has 195 employees. As a supplier of 

pumps, related equipment and servicing to the oil and gas industry the company is important to a number oflarger 

companies in the U.S. energy sector. 

In a short period of time Liberty Lift has become an industry leader in the oil well beam pumping industry. 

Significantly, Liberty Lift is the only company today worldwide that produces a conventional oil well beam 

pumping unit with a minimum clockwise crank rotation of 186 degrees of upstroke. This factor is important 

because the degree of crank rotation in a beam pumping unit affects the efficiency of the beam pumping unit in 

extracting below-ground oil and gas. Conventional oil well beam pumping units marketed and sold by other 

companies typically have a maximum crank rotation of 180 degrees of upstroke and as such, are less efficient 

than Liberty Lift's units. Consistent with the superior efficiency of its oil well beam pumping units, Liberty Lift 

markets the units as High Efficiency (HE) goods. See www.libertylift.com. In that regard, not only is Liberty 

1250 Wood Branch Park Drive, Suite 250, Houston, Texas 77079, 713/575-2300 

PUBLIC VERSIONP.1
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EXHIBIT A 
D'

asram does • 
Product Nomenclature 

Many of the components of a beam pumping unit have common names which may or may not reflect their 

engineering purpose. See Figure J.1 for an illustration of a common pumping unit with these component 

names indicated. 

Figure J,1—Beam Pumping Unit Nomenclature 

Image taken from API Specification HE, Annex J. 

102 
LIBERTY LIFT PUMPING UNIT 
EXHIBIT B 
U.S. Department of Homeland Security 

U.S. Customs and Border Protection 

National Commodity Specialist Division 

One World Trade Center, Suite 51.201 

New York, NY 10007 

U.S. Customs and 

Border Protection 

N299594 

August 27, 2018 

CL A-2-84: OT :RR:N C :N1:102 

CATEGORY: Classification 

TARIFF NO.: 8413.50.0010, 9903.88.01 

Mr. Robert D. Stang 

Partner 

Flusch Blaclcwell LLP 

750 17th St. N.W., Suite 900 

Washington, D.C. 20006-4675 

RE: The tariff classification of an incomplete oil well pumping unit 

Dear Mr. Stang: 

In your letter dated July 31, 2018, on behalf of Liberty Lift Solutions of Midland, Texas, you 

requested a tariff classification ruling. Technical literature was provided. 

The merchandise at issue is an oil well beam pumping unit. The pumping unit's function is to 

displace oil from the bottom of an oil well to the surface. The primary components of the unit 

are a walking beam, the horsehead, the counterweight, the gear reducer and the prime mover. 

The incomplete unit is placed above ground and once connected with various rods and other 

connections, the unit moves downward and upward through the underground tubing to extract 

oil. 

Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) 

is made in accordance with the General Rules of Interpretation (GRI's) 1 through 6. The systematic 

detail of the HTSUS is such that virtually all goods are classified by application of GRI1, that is, 

according to the terms of the headings of the tariff schedule and any relevant section or chapter 

notes. 
2 

In the event that the goods cannot be classified solely on the basis of GRI1, and if the headings and 

legal notes do not otherwise require, the remaining GRI's may be applied, taken in order. 

GRI 2(a), HTSUS states, "Any reference in a heading to an article shall be taken to include a 

reference to that article incomplete or unfinished, provided that, as presented, the incomplete or 

unfinished article has the essential character of the complete or finished article. It shall also be taken 

to include a reference to that article complete or finished (or falling to be classified as complete or 

finished by virtue of this rule), presented unassembled or disassembled". 

In your letter, you suggested classification of the incomplete oil well beam pumping unit in heading 

8413, pursuant to GRI 2(a). This office agrees as the pump unit has the essential character of the 

completed unit at importation. 

As such, the applicable subheading for the oil well beam pumping unit will be 8413.50.0010, 

HTSUS, which provides for Pumps for liquids,whether or not fitted with a measuring device; liquid 

elevators; Other reciprocating positive displacement pumps; Oil well and oil field pumps. The rate 

of duty will be Free. 

The country of origin for the oil well pumping unit is not stated in your letter. However, it 

should be noted that effective July 6, 2018, the Office of the United States Trade Representative 

(USTR) imposed an additional tariff on certain products of China classified in the subheadings 

enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. Subsequently, 

USTR imposed additional tariffs, effective August 23, 2018, on products classified under the 

subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. 

For additional information, please see the relevant Federal Register notices dated June 20, 2018 

(83 F.R. 28710) and August 16, 2018 (83 F.R. 40823). Products of China that are provided for in 

subheading 9903.88.01 or 9903.88.02 and classified in one of the subheadings enumerated in 

U.S. note 20(b) or U.S. note 20(d) to subchapter III shall continue to be subject to antidumping, 

countervailing, or other duties, fees and charges that apply to such products, as well as to those 

imposed by the aforementioned Chapter 99 subheadings. 

Products of China classified under subheading 8413.50.0010, HTSUS, unless specifically 

excluded, are subject to the additional 25 percent ad valorem rate of duty. If the oil well 

pumping unit is a product of China, you must report the Chapter 99 subheading, i.e., 9903.88.01, 

in addition to subheading 8413.50.0010, HTSUS, listed above at the time of importation. 

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring 

the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 

Duty rates are provided for your convenience and are subject to change. The text of the most 

recent HTSUS and the accompanying duty rates are provided on the World Wide Web at 

https://hts.usitc.gov/current. 

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 

C.F.R. 177). 
3 

A copy of the ruling or the control number indicated above should be provided with the entry 

documents filed at the time this merchandise is imported. If you have any questions regarding 

the ruling, contact National Import Specialist Sandra Martinez at Sandra.martinez@cbp.dhs.gov. 

Sincerely, 

ci 

for 

Steven A. Mack 

Director 

National Commodity Specialist Division 
BUSINESS CONFIDENTIAL 

EXHIBIT C 
NOT SUSCEPTIBLE TO PUBLIC SUMMARY
NOT SUSCEPTIBLE TO PUBLIC SUMMARY
NOT SUSCEPTIBLE TO PUBLIC SUMMARY
BUSINESS CONFIDENTIAL 

EXHIBIT D 
i 

NOT SUSCEPTIBLE TO PUBLIC SUMMARY
NOT SUSCEPTIBLE TO PUBLIC SUMMARY
NOT SUSCEPTIBLE TO PUBLIC SUMMARY