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:
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

October 6, 2018

VIA REGULATIONS.GOV PUBLIC DOCUMENT

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516

Washington, D.C., 20006 

Re: Request for Exclusion of FM Transmitters under HTSUS 8525.50.7010 from the Determination of 

Action Pursuant to Section 301

Dear Ambassador Lighthizer:

Scosche Industries, Inc. (“Scosche”) respectfully submits this request for exclusion of FM Transmitters 

from the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1

Scosche was founded in 1980 as a family-owned and operated enterprise, and is based in Oxnard, 

California. Scosche is an internationally recognized, award-winning innovator of consumer technology and car 

audio products. We maintain offices in three U.S. States plus Shenzhen, China and have over 140 employees 

located in four countries. 

Scosche provides car audio installation hardware and portable electronics accessories. It offers dash kits, 

harnesses, antennas and adapters, tools, amplifiers, speakers, subwoofers, speaker enclosures, Bluetooth 

products, interfaces, distribution blocks, power and audio cables, mobile accessories, and installation 

accessories. Scosche’s product portfolio encompasses thousands of skus spanning the consumer technology and 

 1 19 U.S.C. § 2411. 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

car audio arena. Scosche products are sold in over 50 countries by a wide array of the most recognized names 

in retail.

This exclusion request addresses FM Transmitters classified under HTSUS subheading 8525.50.7010, 

which are currently subject to the 25% additional Section 301 tariff. Please note that a separate Section 301 

Investigation Form to Request Exclusion of Product has been submitted for each unique part number for which 

we are requesting an exclusion. 

In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2 Scosche provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China, i.e. whether the particular product and/or a 

comparable product is available from sources in the United States and/or in third countries

The FM Transmitters that are the subject of this exclusion request are not available outside of China. 

Currently, our company sources FM Transmitters from extensively vetted suppliers in China. There is no 

readily available alternative U.S. or third country source outside of China from whom we can source these 

products.

Further, the FM Transmitters cannot be sourced from other countries as all of our tooling, certifications 

and logistics for this product are located in China. To engage new suppliers would entail an onerous process of: 

(1) identifying vertically integrated suppliers, including sub-suppliers, in other countries; (2) once identified, 

making sure such suppliers maintain facilities that adhere to labor laws consistent with US standards; and (3) 

retooling the product in accordance with the specifications of our customers. Our current suppliers have passed 

 2 Procedures To Consider Requests 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, 83 Fed. Reg. 32,181 (USTR July 11, 2018).
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

vital social responsibility, safety and security audits required by U.S. retailers. Scosche is contractually 

required to use audited, certified and approved suppliers. Our suppliers have already been qualified and to 

change suppliers would require us to repeat this process and request a contractual amendment from our 

customer.

With new suppliers, we would have to recertify all suppliers, placing our whole infrastructure in 

jeopardy. We estimate that the recertification process would take a minimum of two years, in addition to 

another year of social responsibility, security and safety audit standards. We expect that lead times for this 

product will more than double due to supply chain constraints and lack of vertical integration. 

Given its reliance on its current supply chain in China, Scosche has significant capital investment in 

tooling in China. Relocations of our tooling outside of China, would cause extended interruptions to Scosche’s 

production. To mitigate the impact of such interruptions, Scosche would need to make significant capital 

expenditures to duplicate its tooling in multiple locations, which would cause extreme financial hardship to our 

company and, as detailed below, threaten our continued operations and employment levels in the United States. 

Our practice of importing FM Transmitters is consistent with that of our leading competitors, which also 

import product from China.

2. Whether the imposition of additional duties on the particular product would cause severe 

economic harm to the requester or other US interests

The FM Transmitters at issue allow consumers to play music and other audio sources through an FM 

Signal. Not all consumers have the latest technology on the vehicles and this would allow them to use their new 

phones to in the vehicle. These products are sold in mass merchant retail with a slim profit margin, providing 

low pricing to the end consumer. Although the FM Transmitters do not support any downstream manufacturing 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

in the U.S., they are a key innovation to the American consumer electronics experience and U.S. consumers rely 

upon these products every day. 

The imposition of 25% duties will have a negative impact on our U.S. profits and employment. These 

products are not an absolute necessity, but they do provide consumers added convenience and an enhanced 

consumer experience. If the pricing increases, consumers may simply decide to no longer use our product. As 

a major supplier of Walmart, BestBuy, and Target etc., the ramifications of losing this line of business would be 

devastating to Scosche and its employees in the United States.

The imposition of a 25% duty increase effectively negates our low profit margin, which would, by 

necessity, be passed directly to our retail customers who have confirmed that increased costs would ultimately 

be passed on to end consumers. Many of our customers have communicated directly with legislators on this 

extremely important issue. These tariffs will directly affect our bottom line, profit sharing and employment 

budget.

3. Whether the particular product is strategically important or related to “Made in China 2025” or 

other Chinese industrial programs

The FM Transmitters are not strategically important, nor related to any other Chinese industrial 

programs, including “Made in China 2025.” Specifically, the FM Transmitters are not a low technology 

product, but they are imported to facilitate the implementation of high technology replacement stereo head units 

in the United States. The product is produced by a non-affiliated third party supplier. 

There are no U.S. patents or trademarks covering this product, and no intellectual property rights have 

been transferred to Chinese producers. These Antennas are produced in China to our specifications and for our 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

exclusive use. We have transferred no intellectual property rights to our suppliers in China nor are we required 

or expected to do so.

We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted,

___________________

Christopher Norris

Global Logistics Coordinator

Scosche Industries

(800) 363-4490, 122

chrisn@scosche.com