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 Version of BCI 

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

The product that we sell under the Volair Sim brand is a metal chassis used as a foundation for building 

an affordable ground flying trainer (simulator). The product consists of a steel frame (chassis), seat, 

optional Avionics Panel and Triple Display Stand, and various mounts and brackets allowing the 

customer to attach necessary accessories (off-the-shelf parts sold by other companies) such as yoke, 

rudder pedals, throttle quadrant(s), displays (monitors or TVs), and various airplane instruments and 

avionics in order to build a low-cost ground-based airplane training device (simulator). 

Our products are used by student pilots, general aviation pilots, US aerospace companies, various 

educational institutions, aviation museums, and several branches and agencies within the US government' 

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/ 

8805290000 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Waclawik, Bart 

BARELLE GROUP LLC DBA Volair Sim 

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

Requestor Representative: 

5. Requestor's relationship to the product: Importer 

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

YES 

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. 

Contains BCI 

VERSION 2 CONTINUED BELOW 1 
8. Is this product, or a comparable product, available from sources in the 'United States? (If you 

indicate "NO", you must provide support for your assertion in Box 12). 

NO 

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

indicate "NO", you must provide support for your assertion in Box 12). 

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: BC I 2017 Quantity: BCI 

2016 Value: BC I 2016 Quantity: BC I 

2015 Value: BCI 2015 Quantity: BC I 

11. Is the Chinese-origin product of concern sold as a final product or an input used in 

the production of a final product or products? 

FINAL PRODUCT 

a) For imports sold as final products, please provide: 

100 % of your total gross sales in 2017 that the Chinese-origin product accounted for. 

b) For imports of inputs used in the production of final products, please provide: 

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for. 

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for. 

VERSION 2 CONTINUED BELOW 2 
12. Please provide information in support your request, taking account of the 

instructions provided in Section B of the Federal Register notice. If you 

responded 'NO" to Questions 8 or 9, you must provide support for your 

assertion in the box below. (Note: text entered below can extend beyond the 

apparent size of this box). 

The product that we sell under the Volair Sim brand is a metal chassis used as a foundation for building 

an affordable ground flying trainer (simulator). Our products are used by student pilots, general aviation 

pilots, educational institutions, aviation museums, and various branches and agencies within the US 

govemment engaged in aviation training and research. 

1. This product is only available from the existing source in China. The design for this product is 

proprietary to our company. Because of the niche nature of the hardware ground flying trainer market, 

there are no comparable alternate sources from third countries. This product requires significant arnount 

of tooling which was incurred by our company over the course of several years. Given the low volume of 

ground hardware flying trainer sales, product retooling and resourcing to a US-based or third country 

manufacturer is not economically feasible as we would not be able to recover tooling and resourcing 

costs. 

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

company, our customers, and US interests. Our products are purchased mainly by US-based individuals 

or institutions engaged in aviation training and education including aviation museums, high schools or 

universities with aviation training programs, US aviation companies, US branches armed forces, and US 

agencies engaged in aviation and space research. Most of our customers are very price-sensitive as they 

are either non-for-profits or subject to budgetary constraints. A duty, which would have to be offset by a 

price increase for our products, would impact the number of ground flying trainer hardware purchased by 

our customers and would have an impact on our sales and profitability. Given already very modest profit 

margins, any further reduction in sales and profitability would require us to lay off staff or potentially 

discontinue operations altogether. 

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

our knowledge. Our ground flying trainer hardware components constitute low volume and low-tech 

products and do not present any significant growth opportunities for China in terms of industrial output, 

job creation, or technological advances. 

VERSION 2 END 
PHOTO 1: Volair Sim Ground Flying Trainer Chassis 
PHOTO 2: Volair Sim Ground Flying Trainer Chassis with optional 

Avionics Panel and Triple Large Display Stand (all electronic hardware and 

software components are furnished and installed by the end customer)