**Identification of Product**

Steel Mold used in conjunction with plastic injection molding machine to form plastic component parts

HTS Code: 

8480.71.8045 

**Purchase History**

Our company made the decision to source the above-referenced mold from China in July 2017.  Our company acquired the above-referenced, custom-made, tool as a one-time purchase.  Our company purchased the tool to allow our U.S.-based injection mold component supplier to manufacture customized plastic components in accordance with our specifications and new product shipment deadline.  

Our supplier shipped the tools in two separate lots: we received the first one on 7/15/18; the other on 7/19/18. 

The total NEV for the mold was $173,320, resulting in a duty of $49,303.31- an unplanned cost increase to us of approximately $43,930.00.

When we began the sourcing process and calculated the costing for the final production of the mold, we based our decision to purchase this mold assuming a duty of 3.1% or $5,372.92.

**Availability of Product Outside of China**

Our company could have sourced the above-referenced mold from other foreign suppliers as well as domestic suppliers.  However, because of the investment we made, the requirements of our business cycle, and the 1 year lead time required to source and validate the injection molding process using the new mold, unfortunately, we could not react quick enough to resource the mold from another supplier. 

Our 2017 business plan designated August 2018 as the release date for a new product.  So we could meet that goal, we started sourcing the mold in July 2017.  

This process entailed 3 months of evaluating vendor capabilities, exchanging engineering drawings, revising technical specifications, and obtaining quotes.  

The mold maker we selected required 6 months lead time to complete the mold.  Once the vendor made the mold, it took roughly 45 days transit time to get the mold to our U.S. injection mold supplier in the U.S. 

After arriving at our supplier’s location in New York State, it took 6 weeks for our supplier to prepare the mold and validate the injection molding process. 

After manufacturing these component parts, the supplier shipped the parts to our facility located in the next town over where they were used to make the end product for sale as a consumer good.  

**Economic Impact**

As stated above, we made the decision to source this mold from China in July 2017.  We chose a local injection mold company to produce our component parts here in the United States.  That U.S. supplier made a significant capital investment in anticipation of receiving component part orders from us using the mold we sourced from China.  Further, we made assurances to our retail vendors that we would have new product ready to ship by the August 2018 deadline.  Had we changed the mold vendor at the time the tariff hikes went into effect, it would have required us to push back the product release date by a year.  Had we done that, we would have lost us future business with our retail customers and our local small business injection mold supplier, resulting in a significant blow to our company’s goodwill and our upstate New York community.  Although we minimized the financial impact to the extent we could, the imposition of the 25% duty on the 2 mold lots we received forced us to make cuts elsewhere, including delaying maintenance on machinery, postponing capital expenditures, and impacting our hiring decisions. 

**Strategic Impact on China**

Our company does not feel that increasing tariffs on steel molds used to make injected molded component parts for consumer sporting goods impacts China’s strategic interests and/or its Made in China 2025 program.   

For the reasons stated above, we respectfully request for an exclusion from the additional *ad valorem* duty of 25% on the above-referenced product.  

Thank you for your consideration.  We welcome any questions you may have.