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:
Item Name Item Description Dimensions HTS Code

LDCO800 Garage Door Operator, 800N, Megacode, DC 

Operator

Dimensions: 17 x 14.75 x 10 inches 

Weight: 20lbs 8428.90.0290

LDO50 Garage Door Operator, 1/2 HP, Megacode 

Operator

Dimensions: 22 x 12 x 10 inches 

Weight: 23 lbs 8428.90.0290

LDCO800-12 Garage Door Operator, LDCO800 GDO Private 

Label - Discount Garage Door

Dimensions: 17 x 14.75 x 10 inches 

Weight: 20lbs 8428.90.0290

LDO33 Garage Door Operator, 1/3 HP, Megacode 

Operator

Dimensions: 17.25 x 12 x 9.75 inches 

Weight: 23 lbs 8428.90.0290

LDCO850 Garage Door Operator, Smart DC Megacode Oper 

1 Led Light

Dimensions: 17 x 14.75 x 10 inches 

Weight: 24lbs 8428.90.0290

AMARR860-12 Garage Door Operator, Entrematic Amarr 860 3 

Led GDO - Precision Door

Dimensions: 17 x 16 x 10 inches 

Weight: 21lbs 8428.90.0290

LDCO852 Garage Door Operator, Smart DC Megacode Oper, 

2 Led Light

Dimensions: 17 x 14.75 x 10 inches 

Weight: 24lbs 8428.90.0290

LCO75 Garage Door Operator, Megacode, LCO75 

Operator

Dimensions: 22 x 12 x 9.75 inches 

Weight: 21lbs 8428.90.0290

LSO50 Garage Door Operator, 1/2HP, Megacode, LSO 

Operator

Dimensions: 22 x 12.25 x 9.6 inches 

Weight: 21lbs 8428.90.0290

AMARR860 Garage Door Operator, Entrematic Amarr 860 3 

Led GDO

Dimensions: 17 x 16 x 10 inches 

Weight: 21lbs 8428.90.0290

LDCO800-17 Garage Door Operator, LDCO800 GDO Private 

Label- Apple Door

Dimensions: 17 x 14.75 x 10 inches 

Weight: 20lbs 8428.90.0290

LDCO852-17 Garage Door Operator, LDCO852 Private Label - 

Discount Garage Door

Dimensions: 20 x 14 x 9.75 inches 

Weight: 20 lbs 8428.90.0290

LDCO800-08 Garage Door Operator, LDCO800 GDO Private 

Label - All Four Seasons

Dimensions: 17 x 14.75 x 10 inches 

Weight: 20lbs 8428.90.0290

LDCO800-15 Garage Door Operator, LDCO800 GDO Private 

Label - Precision Door

Dimensions: 17 x 14.75 x 10 inches 

Weight: 20lbs 8428.90.0290

LDO50-13 Garage Door Operator, LDO50 GDO Private Label - 

Garage Door of Indianapolis

Dimensions: 22 x 12 x 10 inches 

Weight: 23 lbs 8428.90.0290

LDO33-08 Garage Door Operator, LDO33 1/3HP GDO Private 

Label - Apple Door

Dimensions: 17.25 x 12 x 9.75 inches 

Weight: 23 lbs 8428.90.0290

MVP50 Garage Door Operator, MVP, 5011, Mqct

Dimensions: 18.25 x 9.3 x 9.5 inches 

Weight: 30 lbs 8428.90.0290

LDCO852-NB Garage Door Operator, Smart DC LDCO852 No Batt

Dimensions: 20 x 14 x 9.75 inches 

Weight: 20 lbs 8428.90.0290

LDCO850-17 Garage Door Operator, LDCO850 GDO Private 

Label - Discount Garage Door

Dimensions: 20 x 14.6 x 10 inches 

Weight: 24lbs 8428.90.0290

LSO50-2T1KB Garage Door Operator, LSO50 HBT7C 2XMCT3 

MDTK KIT

Dimensions: 22 x 12 x 10 

Weight: 21 lbs 8428.90.0290

LDO50-15 Garage Door Operator, LDO50 GDO Private Label - 

Waynes Overhead Door

Dimensions: 22 x 12 x 10 inches 

Weight: 23 lbs 8428.90.0290

LDO50-09 Garage Door Operator, LDO50 GDO Private Label - 

All Four Seasons

Dimensions: 22 x 12 x 10 inches 

Weight: 23 lbs 8428.90.0290

LSO50-2T1KB8 Garage Door Operator, LSO50 HBT8C 2XMCT3 

MDTK KIT

Dimensions: 22 x 12 x 10 inches 

Weight: 21 lbs 8428.90.0290

AMARR840 Garage Door Operator, Entrematic Amarr 840 1 

Led GDO

Dimensions: 17 x 15.4 x 9.75 inches 

Weight: 23 lbs 8428.90.0290

Nortek Security & Control - Description of Garage Door Operator Products (HTS 8428900290)
 

 

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Via online submission at regulations.gov, docket number USTR-2018-0025

PUBLIC DOCUMENT

September 10, 2018

The Honorable Robert E. Lighthizer

U.S. Trade Representative

Office of the United States Trade Representative

600 17th Street, NW

Washington, DC 20006

Re: USTR-2018-0025 — Nortek Security & Control LLC Request 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; Garage Door Operator Products, HTSUS 8428.90.02.90

Dear Ambassador Lighthizer:

Nortek Security & Control LLC (“NSC”) submits this statement in support of its request to 

exclude certain garage door operator products imported under Harmonized Tariff Schedule of 

the United States (“HTSUS”) classification 8428.90.02.90 from the tariffs imposed pursuant to 

the Notice of Action published by the Office of the U.S. Trade Representative (“USTR”) on 

June 20, 2018 (the “Notice of Action”).1 NSC’s garage door operator products are manufactured 

in an NSC-owned and -operated facility in China in accordance with proprietary designs 

developed by NSC in the United States; there is thus no alternative source for these products 

outside of China. As a result, the tariffs will have substantial adverse impacts on NSC, its 

business partners, and the broader U.S. economy, including specifically on capital investment 

and employment in the United States. Moreover, these products are not relevant to the “Made in 

China 2025” program or China’s other strategic industrial policies.

I. DESCRIPTION OF PRODUCTS

The NSC garage door operator products are all imported under the HTSUS classification 

8428.90.02.90. The specific garage door operator products at issue include garage door 

operators, which are the motor driven, either belt drive and/or chain drive, devices that 

physically open and close the garage door (“garage door operator”).2 Pictures and further 

descriptions of several of these types of NSC garage operator products are included in the Linear 

 1 83 Fed. Reg. 28710 (Jun. 20, 2018). 2 NSC imports several models of garage door operators, including: LDCO800, LDCO800-08, LDCO800-12, 

LDCO800-14, LDCO800-15, LDCO800-16, LDCO800-17, LDCO850, LDCO850-17, LDCO850-NB, LDCO852, 

LDCO852-17, AMARR840, AMARR860, AMARR860-12, LCO75, LDO50, LDO50-09, LDO50-13, LDO50-14, LDO50-

15, LDO33, LDO33-08, LSO50, and MVP50., MM9333H, MM9434K, and MM9545M. 
 

 

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2

Garage Door Operator brochure attached as Exhibit 1 (Linear is one brand name under which 

NSC garage operator products are sold). 

Please note that, as required by the procedures set forth in the Notice of Action, NSC is 

submitting a separate Form to Request Exclusion of Product for NSC’s garage door operator 

products. NSC is submitting this letter in support of, and as a supplement to its Form to Request 

Exclusion of Product.

II. DISCUSSION

A. Overview of NSC’s Garage Door Operator Business and Imports from China

1. NSC’s Investment in U.S. Research & Development and Jobs

Headquartered in Carlsbad, California, NSC is a leading developer and manufacturer of garage 

door operator products, along with other products serving the health and wellness, security, home 

automation, and commercial access control markets, along with audio visual equipment and 

software for the residential audio video and professional video markets. NSC’s history as an 

American manufacturer dates back to 1961, when the company’s founders first started making 

wireless radio controls in California. Today, NSC is a $500 million enterprise employing more 

than 620 people across 10 locations in the United States.3 Approximately 200 of these employees 

are highly-skilled engineers who design and develop products for NSC’s customers, which 

include service companies and integrators in the U.S. and around the world. NSC is proud that its 

U.S. engineers have an average tenure with the company of 10 years, which underscores the 

company’s commitment to be an employer of choice for the highest-skilled and most talented 

U.S. employees.

The size and tenure of NSC’s U.S. engineering team also reflects the central role of high-value 

research and development in the company’s business strategy. Many of NSC’s products are 

designed and developed to meet the special needs of particular customers. For example, NSC’s 

garage door operator products incorporate unique software that enables interactive connectivity 

through wireless devices. NSC’s expertise in wireless engineering allows the company to offer 

custom solutions that are not available from other suppliers.

NSC’s oversight and control of its manufacturing supply chain supports the company’s ability to 

offer this customization. As described in greater detail below, NSC manufactures the vast 

majority of the products designed by its U.S. engineering team at a wholly-owned factory where 

the company has total control over product quality and design. NSC’s control of the 

 3 In addition to NSC’s Carlsbad headquarters, the company has operations in Olive Branch, MS, Petaluma, CA, 

Tallahassee, FL, Lehi, UT, Grand Rapids, MI, Kirkwood, WA, Peabody, MA, San Jose, CA, and Fontana, CA (listed 

in descending order of employee headcount).
 

 

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manufacturing process allows it to make custom modifications expeditiously to meet customer 

needs, while ensuring high levels of reliability. This customization is supported by NSC’s U.S.-

based customer service team, which works closely with integrators and dealers to develop 

custom product solutions.

NSC has plans to build on its competitive strengths in U.S.-based innovation and custom product 

development. The company recently acquired Intellivision, Inc., a San Jose, California-based 

data and video analytics company. As the integration of Intellivision proceeds, NSC is expending 

significant engineering and other resources to develop next-generation security and access 

control technology, and products and services that incorporate advanced analytics and machine 

learning. The acquisition is another reflection of the company’s commitment to locating highvalue research and development in the United States, while leveraging its engineering expertise 

through its unique manufacturing platform. 

NSC is part of the broader Nortek family of companies, which includes other U.S. manufacturing 

subsidiaries focused on the production of heating, ventilation, and air conditioning (“HVAC”) 

equipment for the commercial and residential markets, as well as clean room technology 

offerings.

2. NSC’s Owned and Operated Chinese Manufacturing Facility is a Key 

Element of the Company’s Strategy to Maintain and Enhance Capital 

Investment and Employment in the United States

NSC owns and operates an ISO 9001:2008 certified (and soon to be ISO 9001:2015 certified), 

state-of-the-art, 380,000 square foot manufacturing facility in Shenzhen, China, where 65 

percent of its products are made, including all of its garage door operator products. NSC’s 

Chinese operations allow the company to maintain and grow its investment in U.S. jobs and 

innovation in a highly-competitive industry segment. Since the 1990s, almost every one of 

NSC’s peer companies in the U.S. has gone out of business due to overseas competition. The 

handful of companies that remain have, like NSC, almost entirely shifted manufacturing overseas 

because these operations cannot be conducted economically in the United States.

By locating its manufacturing activities where costs are more competitive, NSC is able to 

support a wide range of high-value activities in the U.S. As noted above, NSC maintains a 

significant engineering presence in the U.S., and all of its executive staff, operations, logistics, 

sales, legal, finance, and distribution personnel are based in this country. These well-paying U.S. 

jobs are part of an U.S. economic footprint that NSC continues to expand. Notably, in 2018 NSC 

invested $9 million to open a new headquarters and engineering center in Carlsbad, California, 

following the $6.75 million development of its new distribution center in Olive Branch, 

Mississippi in 2017.
 

 

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Unlike other U.S. companies that outsource overseas manufacturing to third parties, NSC has 

made its ownership and control of the Shenzhen facility into an area of competitive strength. 

NSC’s operation of the facility allows it to maintain the highest quality standards and seamlessly 

offer custom product solutions that cannot be made anywhere else. This is a competitive 

differentiation that distinguishes NSC from other manufacturers, including others that source 

from China.

This is ultimately a story about comparative advantage among different geographies and business 

climates. NSC has thrived by investing in research and development in the growing U.S. 

technology sector, creating hundreds of U.S. jobs and millions of dollars in economic impact. 

These benefits are made possible by locating relatively lower-value manufacturing activities in 

parts of the world where manufacturing costs are lower.

B. Failure to Exclude NSC’s Products Will Result in Severe Economic Harm to 

NSC and other Critical U.S. Interests 

1. The Subject Products Are Only Available from China and The New 

Tariffs Put NSC’s Entire Supply Chain at Risk, Compromising Its Ability 

to Invest in U.S. Innovation and Employment, And Reducing Competition 

in The Garage Door Operator Market in The U.S.

NSC’s manufacturing facility in China is the only source available for the manufacture of garage 

door operators to NSC’s proprietary designs. Given the cost competitive nature of the garage 

door operator market, the new tariffs put NSC’s garage operator business at risk. The tariffs 

directly endanger the substantial NSC capital investments and employment in the United States, 

including the investments and employment associated with NSC’s product development and 

design activities which occur solely in the United States.

It would be impossible to replicate the control over product quality and supply chain control that 

NSC’s Shenzhen facility provides. Because of the highly-customized nature of NSC’s products, 

shifting production to a third-party factory outside China is not feasible. Developing a new 

company-owned manufacturing facility outside China would be enormously costly in both time 

and resources. As a result, NSC’s wholly-owned facility in Shenzhen is effectively the sole 

source of the products that are the subject of this exclusion request.

Consequently, the tariffs imposed by the Notice of Action must either be absorbed by NSC at 

considerable cost or passed on to its customers. Neither option is attractive, and both would 

result in severe economic damage to NSC’s business, provide consumers with fewer options, and 

lead to higher prices. 
 

 

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The new tariffs will also uniquely disadvantage NSC in the garage door operator market. Some 

of NSC’s most significant competitors have elected to locate their manufacturing in Mexico, and 

their products are thus not subject to the tariffs. This situation makes it extremely difficult for 

NSC to pass along price increases to its customers without losing business to lower-price 

competition. The largest of these competitors has an industry market share of approximately 80 

percent. Any price increases by NSC will allow this single company to capture an even larger 

share of the market and substantially reduce competition in the U.S. market. 

NSC is a driving innovative force in the garage door operator market, and the products that are 

subject to the new tariffs are highly valued by customers. NSC’s garage door operator products 

are elements of its total offering of devices that ensure a safe and secure home or business, so 

these price increases will have the added effect of making other NSC offerings less attractive to 

its customers. As NSC’s market share declines across its business segments so too will its ability 

to invest in its U.S. operations, including its high-value research and development activities. 

Simply put, absorbing the tariffs would completely erode NSC’s margins on the relevant 

products, leaving the company unable to support further investment in innovation and business 

growth. 

[ 

 ]

2. The Tariffs Potentially Will Adversely Impact U.S. Capital Investments 

and Employment by other NSC Affiliated Companies

NSC and its affiliated companies, which are U.S.-based, operate a diverse array of businesses in 

addition to the garage operator business and maintain substantial capital investments and 

employment in the United States. NSC is also a leading developer and manufacturer of security 

and home automation and access control technologies for the residential and commercial markets 

as well as a leading developer of health and wellness products and supplier of audio/visual 

technology for the residential and professional markets. NSC-affiliated companies develop and 

manufacture a wide range of products, from HVAC products to ergonomic office furniture to 

residential ventilation equipment and central vacuums. Any adverse impact on the garage door 

operator business, and certainly the loss of that business, would also potentially have an adverse 

impact on capital investment and employment in the United States in connection with other NSC 

and affiliate business operations.
 

 

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3. The Tariffs Will Adversely Impact Other U.S. Manufacturers, 

Distributors, and Installers of Garage Door Operator Products that Rely on 

NSC Products

Nearly all of NSC’s sales of garage door operator products are to distributors, dealers, and 

resellers. These distributors and dealers rely on NSC’s supply of product to reach consumers. 

For example, certain NSC garage operator products are manufactured in accordance with 

customer requirements and those customers utilize NSC as an Original Equipment Manufacturer 

to design, manufacture, and integrate NSC products with a reseller’s products under the reseller’s 

brand name as cornerstone products in the reseller’s product line. The new tariffs will put strain 

on, or eliminate entirely, partnerships such as this where NSC can leverage its supply chain 

efficiencies afforded by its Shenzhen factory to supply customized product to resellers.

Further, because the garage door operator market in the United States has a limited number of 

suppliers, it is very price competitive. However, any impact on NSC must at least be partially 

passed on to NSC’s customers – the resellers, distributors and installers NSC supplies – for NSC 

to avoid operating at a loss. These increased costs will cause an adverse impact on thousands of 

partners NSC has in the garage door operator market, jeopardizing these partners’ capital 

investments and employment. 

4. The Tariffs Will Reduce the Availability of Innovative and CostCompetitive Garage Door Operator Products to the U.S. Consumer

The U.S. garage door operator market is highly concentrated and price competitive. NSC’s 

vigorous, ongoing research and development activities are required to continue to offer high 

quality, innovative products to consumers at competitive prices in the United States market. Any 

increased costs due to tariffs will make it difficult for NSC to maintain its current level of 

research and development efforts in the United States which will have adverse effects on U.S. 

consumers by reducing high quality product choices and competitive pricing.

C. NSC’s Garage Door Products Are Not Strategically Related China’s 

Industrial Policies

1. NSC’s Garage Door Products Lack the High-Tech Characteristics 

Targeted by China 2025 

Application of the proposed tariffs to NSC’s products is inconsistent with the stated purpose of 

the Notice of Action, which was to impose higher tariffs on “goods imported from China 

containing industrially significant technology, including those related to the ‘Made in China 
 

 

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2025 program.’”4 The focus of Made in China 2025 is the Chinese capture and development of 

emerging high-tech products and industries. 

NSC has been manufacturing and designing garage door operator products for decades. For 

approximately twenty years, NSC has manufactured its garage door operator products at its 

Shenzhen factory using the same or similar practices from its outset. Because garage door 

operator products are not strategically important technologies that confer a competitive 

advantage on their country of manufacture, garage door operator products do not fall directly 

under any of the ten “priority sectors” as identified by the Made in China 2025 plan.5 NSC’s 

garage door operator products are not part of an emerging technology sector, and thus, are not a 

focus of China’s push to expropriate new technologies or industrial practices from the United 

States. 

2. NSC’s Products Have Been Developed with U.S. based Intellectual 

Property and the Imposition of Tariffs Threaten Further Domestic 

Development

The August 14, 2017 Presidential Memorandum that launched USTR’s investigation of Chinese 

technology and intellectual property practices focused on measures that “inhibit United States 

exports, deprive United States citizens of fair remuneration for their innovations, divert 

American jobs to workers in China, contribute to the United States’ trade deficit with China, and 

otherwise undermine American manufacturing, services, and innovation.”6 However, NSC 

strategically owns and operates its own Shenzhen manufacturing facility and has substantial 

control over its entire supply chain, including in China, while enjoying the benefits of being 

highly vertically integrated as part of a comprehensive strategy to protect NSC’s intellectual 

property portfolio and promote the development of new inventions. Through NSC’s ownership 

of its Shenzhen factory NSC has instituted its own quality, safety, and confidentiality measures. 

These measures ensure that NSC remains in possession of all the NSC patents, copyrights, and 

trade secrets practiced and utilized by its garage door operator products.

3. NSC’s Garage Door Operator Products Constitute A Small Fraction of the 

Products Imported Under HTSUS 8428.90.02

Finally, the aggregate value of all products imported from China under this 8-digit subheading in 

2017 was approximately $176.5 million. In that same year, the total value of all garage door 

operator products imported from China by NSC was approximately $12 million. This amounts to 

6.8% of all products imported under the HTSUS 8428.90.02 subheading. The de minimis nature 

 4 See 83 Fed. Reg. 28711. 5 2025 [Made in China 2025] (State Counsel, May 8, 2015), available at http://www.gov.cn/zhengce/content/2015-

05/19/content_9784.htm

6 Presidential Memorandum, 82 Fed. Reg. 39007 (Aug. 17, 2017).
 

 

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of NSC’s imports of these products from China relative to the broader subheading means that the 

requested carve out will not undermine USTR’s goals with respect to the Notice of Action and 

this HTSUS code.

D. CBP Can Easily and Effectively Administer this Exclusion

United States Customs and Border Protection (“CBP”) will be able to easily administer an 

exclusion for NSC’s garage door operator products because of the company’s exclusive control 

over their manufacturing and shipment to the U.S., and because NSC’s garage door operator 

products are imported exclusively under the 10-digit HTSUS 8428.90.02.90 classification. All 

NSC garage door operator products are identified in their Commercial Invoice, the document 

used by CPB to identify and determine admissibility of goods imported7, with the uniform prefix 

of “Garage Door Operator.” Thus, in order to identify and effectively exclude the Garage Door 

Operator Products CBP need only look to the uniform description listed on Commercial Invoice 

provided upon import. Further, as evidenced by three administrative rulings published since 

2000, CBP has an intimate familiarity with this particular HTSUS code and garage door operator 

products.8

Moreover, unlike other products that fall under the broader HTSUS subheading such as vertical 

conveyors or car lifts all NSC garage door operator products have similar size and weight 

characteristics, approximately 18” x 14” x 10” and falling between 21 and 24 lbs., making them 

easily identifiable and distinguishable from the other lifting products classified under HTSUS 

8428.90.02.90 code. 

III. CONCLUSION: THE REQUESTED EXCLUSION OF GARAGE 

OPERATOR PRODUCTS IS NECESSARY TO AVOID SEVERE 

ADVERSE IMPACTS ON NSC AND THE U. S. ECONOMY AND WILL 

NOT UNDERMINE THE PURPOSES OF THE SECTION 301 TARIFF 

INITIATIVE

Without the requested exclusion, the tariffs imposed by the Notice of Action seriously endanger 

the nearly six decades of investment that NSC has made in the United States. Penalizing NSC’s 

decision to focus its U.S. operations on high-value research and development activities is out of 

step with the Administration’s policy goals and threatens a significant number of well-paying 

jobs and millions of dollars worth of economic contributions to communities across the country. 

Worse, the tariffs will have the effect of picking “winners” and “losers” among players in a 

highly competitive industry based solely on the foreign country where they choose to locate 

 7 See 19 CFR 141.85

8 See CBP Ruling, CLA-2-84:OT:RR:NC:N1:106, CBP Ruling, CLA-2-84:RR:NC:1:103, CBP Ruling
 

 

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manufacturing. Finally, the types of products involved do not reflect the focus of the Section 301 

tariff initiative. Therefore, for the reasons stated above, NSC respectfully requests that USTR 

exclude garage door operator products imported under HTSUS classification 8428.90.02.90

from the list of products subject to tariffs in connection with the Notice of Action.

Thank you for your consideration. If you have any questions regarding NSC’ request, please 

contact Nicholas Janda, Director and Legal Counsel at 760.231.0938 or our counsel, Stacy 

Ettinger, K&L Gates, at 202.778.9072.

I, Nicholas Janda, certify that the information provided herein is complete and correct to the 

best of my knowledge. 

Nicholas Janda

Director and Legal Counsel
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• WiFi connectivity with the Linear app

• Real-time monitoring and control of 

garage door — anywhere, any time

• Up to ten authorized users

• Set custom access and permissions 

for each user

• Scheduling of door and light operation, 

including timed, automatic door closing

• Custom skills and actions for Amazon 

AlexaTM, Google AssistantTM, and 

IFTTTTM
Our Lineup

• Energy Efficient

• Quiet/Smooth

• Powerful 

• Residential/Light Duty

Commercial

Offering 1-2-3 Flexibility

1. Choose a Head

AC, DC, 1/3 to 3/4 HP

2. Choose a Rail

Belt or Chain, T or I-Beam

3. Add Accessories

I-Beam Conversion Rails, 

Multifunction Transmitters

and Keypads

Quick and Easy to Set Up

• Interchangeability of Common

Components

• Pre-assembled/tensioned Rails

• Installation and Set-up Simplicity

LCO75 | Many Doors, One Operator

• 3/4 HP AC Motor

• Our most versatile and powerful operator 

• Suited for light-duty commercial and residential

carriage house-style doors 

• Vibration-isolation hangers

• Pre-assembled and pre-tensioned rails for quicker, 

simpler installations 

• All sensitivity, limit adjustments on the same side of operator

• Built-in diagnostics 

• Deluxe Wall Station and 3-Channel Visor Transmitter included

LSO50 | Smooth, Quiet Operator

• 1/2 HP AC Motor

• Smooth, quiet operation

• Belt drive or chain drive

• Dual 100 watt courtesy lights

• Vibration-isolation hangers

• Noise-reduction technology

• Deluxe Wall Station and 3-Channel Visor Transmitter included

LDCO800 | One Smooth Operator

• 800 Newton DC Motor for lifting heavy doors

• Smooth start/soft stop for ultra-smooth, quiet, and long-term 

reliable performance

• No loss of speed vs. AC operators

• Electronic limits for quick and easy setup

• Intelligent, self-learning, self-adjusting torque settings

• Low standby power and high-efficiency power design

• Deluxe Wall Station and 3-Channel Visor Transmitter included

• 100 watt courtesy light

• Battery Backup Compatible

• Built-in MegaCode format receiver

LDO50/33 | Rock-Solid Performance

• 1/2 HP and 1/3 HP AC Motor

• Rock-solid performance

• Belt drive or chain drive

• 100 watt courtesy light

• Deluxe Wall Station and 3-Channel Visor Transmitter included

LDCO850 | One Smooth Smart Operator

• Smart connectivity via WiFi communication protocol

• 800 Newton DC Motor for lifting heavy doors

• Smooth Start/soft stop for ultra-smooth, quiet, and long-term reliable performance

• No loss of speed vs. AC operators

• Electronic limits for quick and easy setup

• Intelligent, self-learning, self-adjusting torque settings

• Low standby power/high efficiency design

• Single LED light

• Battery Backup Included

• Built-in Megacode format receiver

• WiFi Wall Station and 3-Channel Visor Transmitter Included

LDCO852 | Smart Connectivity, Dual LED

• Smart connectivity via WiFi communication protocol

• 800 Newton DC Motor for lifting heavy doors

• Smooth Start/soft stop for ultra-smooth, quiet, and long-term reliable performance

• No loss of speed vs. AC operators

• Electronic limits for quick and easy setup

• Intelligent, self-learning, self-adjusting torque settings

• Low standby power/high efficiency design

• Dual LED light

• Battery Backup Included

• WiFi Wall Station and 3-Channel Visor Transmitter Included

• Built-In MegaCode format receiver 3
All sensitivity, limit adjustments 

and transmitters set on the 

same side of the head Built-in diagnostics and 

trouble shooting guide 

on operator

Snap-in, non-polarized 

obstacle-sensing beams 

are sonically sealed

to prevent water 

intrusion and can be 

mounted to track or wall

Linear's extraordinary 

attention to design details 

enables you to zip right 

through each job.

Non-polarized wall station 

can mount to a single-gang 

electrical box or directly

to the wall

Optional field-installed I-Beam 

conversion rail can be added 

to increase rigidity

Simple Installation

Fast and easy rail 

connection

Pre-tensioned and 

pre-adjusted chain 

and belt rails

4
Loaded 

All Linear operators come packed with standard features that are 

added-cost options elsewhere — if available at all.

• Gears mounted in transmission-type case

• One control board for all functions (AC units)

• Worm gear ends reinforced with steel sleeve

• Drive shafts aligned with bronze, oil-filled bushings

• Built-in self diagnostics

• Built-in vibration isolator on hanging brackets

(LSO and LCO models only)

Tested 

We test all our operators — not just as individual components, 

but as complete systems. 

• 13-point function test: head to chain or belt, obstacle 

sensors to radio

• Results posted inside the operator case

Backed

We stand behind our operators by offering the industry’s most 

generous warranties — and the industry’s best customer support.

• Lifetime warranty on LCO, LDCO, LSO and LDO 1/2 HP motors

• Lifetime warranty on HBT belts

• 10-year warranty on LDO 1/3 HP motors

• 5-year warranty on HCT chains

• 5-year warranty on mechanical parts

• 1-year warranty on electronics

• East and West Coast distribution centers

• Industry's most knowledgeable and experienced 

field sales and service network

We Have Your Back

5
Standard Equipment

In addition to your choice of head units and belt or chain rail in multiple lengths, Linear 

systems come supplied with an easy-to-install obstacle sensing system (includes 35 feet of 

wire on each beam and 20 feet for wall station), all necessary mounting hardware and the 

following items:

Deluxe Wall Station

• Controls for Up/Down/Stop, lights, vacation switch On/Off

• Backlit LEDs always on to enable users to find controls in the dark

WiFi Wall Station

• Controls for Up/Down/Stop, On/Off/Dim lights, turn vacation mode on/off and for pairing 

the GDO to a WiFi access point for smart operation

• Multiple LED indicators to tell the user the status of vacation mode and WiFi connectivity

MTR-3 3-Channel Visor Transmitter

• Three channels — homeowners with three operators (or who live in a gated community) 

need only one remote per car

• Red LED lets user know unit is transmitting

• Dual-position visor clip

Obstacle-Sensing Beams

• Snap-in, non-polarized, obstacle-sensing beams

• Sonically sealed to prevent water intrusion

Standard and Optional Equipment

Deluxe

Wall Station

MTR-3 3-Channel

Visor Transmitter

Obstacle-Sensing 

Beams 

6

WiFi

Wall Station

Model Power Warranties Standard Equipment Options

LCO75

Belt or Chain Drive 3/4 HP

AC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Dual lamps

• 7, 8, 10 ft. T rails

• 12, 14 ft. I rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

LSO50

Belt or Chain Drive 1/2 HP

AC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Dual lamps

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

LDCO800

Belt or Chain Drive 800 Newton

DC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Single lamp

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

• Battery backup

LDO50

Belt or Chain Drive 1/2 HP

AC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Single lamp

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

LDO33

Belt or Chain Drive 1/3 HP

AC Motor

10-Year / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Single lamp

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

LDO850

Belt or Chain Drive 800 Newton

DC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Single lamp

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

• Battery Backup

LDO852

Belt or Chain Drive 800 Newton

DC Motor

Lifetime / Motor

Lifetime / Belt

5-Year / Mechanical parts

1-Year / Electrical parts

• Deluxe Wall Station

• MTR-3 3-Channel Visor Transmitter

• Obstacle-Sensing Beams

• Single lamp

• 7, 8 ft. T rails

• CHCR I rail Conversion Kit

• Complete family of MegaCode 

transmitters and receivers

• Battery Backup
MegaCode Radio Controls

Choose from the industry’s widest selection of add-on radio controls.

TRANSMITTERS

ACT-21 – 1-Channel Keychain 

ACT-22 – 2-Channel Keychain 

ACT-31B – 1-Channel Keychain

ACT-34B – 4-Channel Keychain

LPWKP-G – Residential Wireless Keypad

MTR-1 – 1-Channel Visor

MTR-3 – 3-Channel Visor

MDT-1A – Deluxe 1-Channel Visor

MDT-2A – Deluxe 3-Channel Visor

MDT-4A – Deluxe 4-Channel Visor

RECEIVERS

MDR/U – 1-Channel 110 V Universal 

Plug-In Receiver

MDR-2 – 2-Channel Receiver

MDRG – 1-Channel Gate Receiver

SMDRG – 1-Channel Extended-Range 

Receiver

AP-5 – Gate/door Operator Controller

TEST EQUIPMENT

FT/1 – RF Field Tester

ACT-31B

ACT-34B

LPWKP/ LPWKP-G

MTR-1

MDR/U

7

BBU

Battery Backup 

option for the 

LDCO800

Optional Equipment

Rails

All Linear rails are of one-piece, rolled-steel construction

and are flush-mountable to ceiling. Belt rails carry a lifetime belt warranty.

Model Description Features CHCR Models for

I rail Conversion

HBT7C 7' Belt T rail • Pre-tensioned, steel-reinforced belt

• Interchangeable with all heads CHCR 7/8

HBT8C 8' Belt T rail • Pre-tensioned, steel-reinforced belt

• Interchangeable with all heads CHCR 7/8

HBT10C 10’ Belt T rail • Pre-tensioned, steel-reinforced belt

• Recommended with LCO75 CHCR 10

HCT7C 7' Chain T rail • Pre-tensioned chain drive

• Interchangeable with all heads CHCR 7/8

HCT8C 8' Chain T rail • Pre-tensioned chain drive

• Interchangeable with all heads CHCR 7/8

HCT10C 10’ Chain T rail • Pre-tensioned chain drive

• Recommended with LCO75 CHCR 10

HCI12 12' Chain I rail

• Pre-tensioned chain drive

• Recommended with LCO75

• For light commercial doors

I rail standard

HCI12 with

HCI+2 14' Chain I rail

• Pre-tensioned chain drive

• Recommended with LCO75

• For light commercial doors

I rail standard

CHCR-7/8 7' or 8' I rail conversion

CHCR-10 10' I rail conversion

Specifications (Individual shipping weight, overall length)

HCT7C/HBT7C

(21 lbs/18 lbs)

HCT8C/HBT8C

(23 lbs/20 lbs)

HCT10C/HBT10C

(27 lbs/24 lbs)

HCI12

(54 lbs)

HCI12 + HCI+2

(54 lbs + 8 lbs)

LCO 75

(25 lbs) 126.5” 141” 161.5” 193.8” 217.3”

LSO50

(21 lbs) 126.5” 141” — — —

LDCO800

(16 lbs) 124.5” 139” — — —

LDO50/33

(20 lbs) 122” 136.5” — — —

LDO850

(16 lbs) 124.5” 139” — — —

LDO852

(16 lbs) 124.5” 139” — — —
We put you in Gate Control

Linear offers swing, slide and barrier gate operators for every 

application — multi-family, commercial and residential — for any type, 

size and weight of gate. Put them together with Linear control systems for 

a complete entry solution!

We put you in Access Control

From garage to gate to total access control, Linear can supply you with 

superior systems and advantage-rich add-ons.

• Telephone Entry Systems

• Keypads

• Stand-Alone Receivers

• Access Controllers

• Proximity Card Readers

• Transmitters

We put you in Radio Control

Linear's most popular family of radio controls.

310 MHZ frequency and 256 dip switch-settable codes.

One of our industry’s top brands. 

A choice of 300 or 310 MHz frequency

and 1,024 dip switch-settable codes.

Our most secure and versatile format.

318 MHz frequency and over 1,000,000 factory 

programmed codes. 

These 310 MHz controls are Stanley compatible. 

One-channel models offer 1,024 dip switch-settable 

codes; two-channel models, 512 codes.

Ideal for residential or commercial uses.

318 or 288 MHz frequency with up to

19,000 changeable codes.

STANLEY

COMPATIBLE

Copyright © 2018 Nortek Security & Control LLC. All rights reserved. Linear is a registered trademark of Nortek Security & Control LLC. 

All other products or name brands are trademarks of their respective holders. Specifications and product availability subject to change 

without notice. Connect with us today—NortekControl.com or 1.800.421.1587.

Nortek Security & Control | 5919 Sea Otter Place | Suite 100 | Carlsbad, CA 92010 | 800.421.1587 | linear-solutions.com

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