Monday, October 1st, 2018

Ambassador 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 – Procedures to Consider Requests for Exclusion of 

Particular Products from the Determination of Action Pursuant to Section 

301: Single row radial ball bearings with an outer diameter measuring at 28mm. 

Product is considered a complete bearing assembly (SUJ2 steel) comprised of 

inner/outer rings, a retainer/cage, a seal, and steel ball rolling elements. (HTS# 

8482.10.5044)

Dear Ambassador Lighthizer:

NSK Americas, Inc. and its US subsidiaries are designers, engineers, and manufacturers 

of advanced motion and control technologies that includes anti-friction bearings, steering 

columns, bearing components, and precision products for supply to key US industrial and 

automotive customers and for export outside the US. We employ over 2,400 people in the US in 

design, engineering, manufacturing, technology, financial, and many other capacities. Annually 

we invest in excess of $25m expanding and enhancing our US businesses.

The subject material that we currently source from our Chinese suppliers is presently not 

available domestically. Developing alternative sources would require comprehensive planning 

lasting a minimum of 12 to 18 months, along with an additional 6 to 8-month implementation 

delivery cycle, given the safety critical applications related to its various end uses. These NSK

bearings are designed to produce the desired motion and reduce friction between two moving 
parts to provide maximum reliability, durability, and performance in a range of the key 

applications they are used in. As a result, quickly changing production locations is not a viable 

option. Our current dependence on China sourcing, similar to other global purchases our 

company makes, supports a wide-range of industrial applications and technologies that include 

primary industries (iron and steel, paper, wind energy, mining, agricultural, etc), processing 

industries (food and beverage, petrochemical, and aftermarket vehicle components), machine 

tooling and plant construction (electric motors, blowers, fans, gears, pumps/compressors) and 

even consumer goods (washing machines, drills, dishwashers and computers). 

Furthermore, the reason NSK decided to source from China is due to cost 

competitiveness, especially in the electric motor market. Our US based plants (Clarinda, IA and 

Franklin, IN) are mostly automotive based production plants with very high volumes and a 

limited number of customers. This required NSK's Industrial and Aftermarket business to find 

overseas plants to help support the lower volumes and unique production requirements of our 

myriad customers in this complicated business segment. It is also worth noting that over the past 

five years we have exited $6M in deep-groove ball bearings that we formerly produced in the US 

(for the electrical segment) due to China price points. However, we did not simply start buying 

“cheap” bearings from a Chinese company. We transferred this business to an NSK plant in 

China so that we could be assured of receiving bearings manufactured to NSK’s 

uncompromising quality and safety standards. 

Additionally, the imposition of these Section 301 duties had a direct, immediate, and 

severe impact to our company, which we have already absorbed from a cost standpoint. This has 

affected both sales and profitability (profit margin) across our internal business segments. We 

have had to also pass on a portion of the tariff cost to our customers (who use our bearings in 

their US manufacturing process) which will eventually hurt the ultimate end user - the individual 

consumer.
We are also not aware of any impact the production of the subject bearings have had as it 

relates to the "Made in China 2025" initiative or any other Chinese industrial based program.

This is due to the fact that bearing design and development has been traditionally considered 

low-tech. 

Please note that NSK Corporation, to our knowledge, has not been harmed by any China 

policies and/or practices as it relates to Intellectual Property Rights, including the transfer of 

technology. Moreover, anti-dumping on majority of bearings and its respective sub-components 

was removed as recently as mid-2014 when USITC ruled anti-friction bearings were not being 

sold below US market value, further justifying the exclusion of any type of additional duties.

Lastly, NSK is unaware of any potential issues that would affect the ability of US CBP to 

administer subject exclusion. CBP should be able to easily identify the products based on 

HTSUS code, MID, and country of origin.

As such, we respectfully request exclusion from Section 301 for our product classified 

under HTS# 8482.10.5044, which is produced and sourced from China.

Sincerely,

Steven A. Beckman

NSK Americas, Inc. 

Chief Executive Officer 

beckmas@nsk-corp.com

(734) 913-7500