Section 301 Investigation: China's Acts, Policies, and Practices Related toTechnology 

Transfer,Intellectual Property, and Innovation - Form to Request Exclusion of Product

When submitting a product exclusion request using this form, enter the specified 

informationinthefollowingfieldsandexplainthebasisandrationaleforyour statements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge.

1. Indicate whetherthe comment containsbusiness confidentialinformation(BCI),is apublic

document, or is a public version of a BCI document.

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

3. 10-digitHTSUSitemnumber*forproductyouwishtoaddressinthisproductexclusionrequest:

*Use numerical characters only with nospecial characters (example: 1023456789). For help infinding 

the HTSUS item number associated with your product, see https://hts.usitc.gov/

8525.60.1040 

4. Requestor Information

Requestor Name (Last, First):

Organization Name:

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

Requestor Representative:

5. Requestor's relationship to theproduct:

6. Does this submission in regulations.gov include additional attachments?

7. Pleaseindicatewhether anyadditional attachment containsbusiness confidential 

information (BCI), is a public document, or is a public version of a BCI document.

No

Public Version

The requested exclusion is for VHF two-way radios designed for marine applications. The specific 

Cobra-brand model at issue is MR F77B/W GPS (in black and white variations), which is a 25-watt, class 

D marine radio. The unit is composed of plastic, steel, aluminum and electronic components. Detailed 

product specifications, including dimensions, are attached.

The radios are designed to be mounted in a boat. 

No

Linda J. Engell, V.P. Supply Chain & Operations

Cedar Electronics Corporation

Importer

Barnes, Richardson & Colburn – Lawrence M. Friedman
8. Is thisproduct, or a comparableproduct, available from sources intheUnitedStates?:

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

10. Please provide thevalue andquantity (withunits) oftheChinese-originproduct of concern 

thatyoupurchasedforeachcalendaryearspecified.Limitthisfiguretotheproducts 

purchased by your firm (or by members of your trade association) alone. Please provide 

estimates if precise figures are unavailable.

2015 2016 2017 2018 (Est.)

Units [Table Redacted]

Dollars

11. Please provide information in support yourrequest, taking account ofthe instructions 

providedin SectionB ofthe Federal Register notice (note: text entered below can extend 

beyond the apparent size ofthis box).

No

Yes
The Cobra radio brand dates back to 1963 when Dynascan, the predecessor company, brought its first CB 

radios to the marketplace. After diversifying into other products including radar detectors, police 

scanners, cordless phones and answering machines, Cobra entered the marine radio and navigation market 

in 2003. Cobra is now a brand of Cedar Electronics, which also produces a full line of dash cameras and 

power accessories. Cedar has 141 employees in the United States in its Chicago, Illinois and West 

Chester, Ohio locations. These U. S.-based employees include manufacturing support and engineering for 

the design and development of new products including marine radios and CB radios integrated via 

Bluetooth with smartphones. 

Severe Economic Harm 

Because there are no manufacturers of marine radios in the U.S., the current 25% duty creates a 

significant competitive disadvantage for Cobra. Cobra estimates an annual cost of [

]. Our contribution margin is [ ]. Absorbing 

the additional cost would [ ]. Ninety-five percent of 

boats in the U.S. are small, towable vessels under 26 feet in length. Seventy-two percent of boaters in the 

U.S. have an annual household income of less than one hundred thousand dollars ($100,000). Based on 

these figures, the majority of customers for Cobra's marine radios are working class individuals 

purchasing a necessary safety device. As a result of these duties, these individuals will see the cost of 

Cobra safety equipment increase. Faced with that reality, Cobra's customers will probably stop buying the 

"American" brands available to them to instead buy the cheaper Japanese product. 

Available Source Countries 

Marine band radios are manufactured in China, Japan and Vietnam. They are manufactured using a 

mature technology with no alternative use, as such, it is unlikely that a company will invest in establishing 

a manufacturing facility to create these products. Cobra is the market leader with a [ ] market share in 

North America for vessels at or below 30 feet in length. Cobra's main competitors are: 

Company Headquarters Manufacturing Est Market Share

Uniden Japan Vietnam 21%

Icom Japan Japan 11%

Raymarine United Kingdom China 4% 

Simrad Norway China 2%

Standard Horizon USA China 23%

Garmin USA China 5%

All U.S.-based marine radio companies are manufacturing in China. Therefore, all U.S. manufacturers 

will be negatively impacted by this duty with a correlating benefit to the Japanese companies. 

Made in China 2025 

While Cobra continues to innovate, marine band radios are a mature technology that is critical for the 

safety and communications of boaters nationwide. There is no indication that short-range, mobile radio 

transceivers have or will benefit from China's policies relating to intellectual property rights and 

technology transfer. Marine band radios are not part of the Made in China 2025 initiative. These products 

have no application to cloud computing, the Internet of Things, autonomous vehicles, agricultural 

equipment, semiconductors, and battery technology. Thus, removing marine band radios from the list of 

items subject to the 301 duties does not further the interests and policies these duties are intended to 

combat.

Ease of CBP Administration

Fix mounted marine radios are the only items in HTSUS item 8525.60.1040. Thus, they are easily 

distinguishable among products in this 8-digit classification.
CLASS-D

FIXED MOUNT VHF RADIO

The latest in Class-D Digital Selective 

Calling (DSC) Technology.

Built in GPS Receiver

Simply connect the radio to power 

and the radio will know your location.

Rewind-Say-Again®

Replay missed VHF calls. 

Automatically records the last 20 

seconds with a digital voice recorder.

Large LCD screen

Large and bright LCD screen

for easy viewing.

PA Output

PA function for public address to 

external speaker.

Submersible

Designed to IPX8 (JIS8) standards.

All NOAA weather channels

Instant access to national 

All Hazards and weather 

information, 24 hours a day.

Softkey Operation

Easily make calls, activate advance 

features and navigate through menus.

Automatic Radio Check

Checks battery voltage when transmitting, RF power output, and 

antenna output. 
Cobra®, CobraMarine®, Nothing Comes Close to a Cobra®, and the snake design are registered trademarks of Cobra 

Electronics Corporation, USA. Cobra Electronics CorporationTM is a trademark of Cobra Electronics Corporation, USA.

©2014 Cobra Electronics Corporation, 6500 West Cortland Street, Chicago, IL 60707, USA

MR F77W GPS SP 11/14 Nothing Comes Close to a Cobra®

Number of Channels All: U.S.A., Canadian, 

International

10 NOAA Weather Channels

Channel Spacing 25 kHZ

Modulation 5 kHz Max.

Input Voltage 13.8 VDC

Current Drain:

 Stand-by 200 mA

 Receive 300 mA

 Transmit 5 A @ High Power

1 A @ Low Power

Temperature Range -20oC to 60oC

Unit Dimensions 6.25” x 2.25” x 7.125”

(159 mm x 57 mm x 180 mm)

Unit Weight (Lbs) 2 lbs., 6.8 oz. (1100 g)

Receiver

Frequency Range 156.050 to 163.275 MHz

Receiver Type Double Conversion 

Super-Heterodyne

Sensitivity:

 20 dB Quieting 0.35 uV

 12 dB Sinad 0.30 uV

AF Output 4 Watts @ 8 Ohms

Transmitter

Frequency Range 156.025 to 157.425 MHz

RF Output Power 1 or 25 Watts

Spurious Emissions -75 dB @ High Power

-72 dB @ Low Power

Microphone Type Electret

Microphone Impedance 2000 Ohms

Frequency Stability +/-10 ppm

FM Hum & Noise 50 dB

GPS

Receiver 56 channels

Acquisition Times:

Hot Nominal: < 1 second, Limit: +/- 5 seconds

Warm Nominal: < 33 second, Limit: +/- 5 seconds

Cold Nominal: < 35 second, Limit: +/- 10 seconds

Update Rate Up to 5 Hz

Antenna Type Internal patch antenna

GPS receiver first lock sensitivity Nominal: -144dBm, 

Limit: 142dBm

GPS receiver tracking sensitivity Nominal: -160dBm, 

Limit: 155dBm

Differential System Compatibility WAAS (United States), 

EGNOS (Europe), 

MSAS (Japan), 

GAGAN (India)

NMEA Info:

Output Specification NMEA 0183- ASCII serial output

Selectrical Standard EIA-422

NMEA Sentences DTM, GGA, GLL, GRS, GSA, GSV, 

RMC, VTG

Packaging Specifications

Individual Clam/Box 3.70”H x 13.10”W x 9.10”H 

Dimensions

Individual Clam/Box Weight 3.7 lbs.

Master Pack Qty. 2

Master Pack Dimensions 9.80”H x 13.80”W x 8.10”D

Master Pack Weight 9.40 lbs.

SKU # (White) MR F77W GPS

UPC # 0 28377 20183 7

Master Pack Barcode 5 0028377 20183 2

SKU # (Black) MR F77B GPS

UPC # 0 28377 20187 5

Master Pack Barcode 5 0028377 20187 0

Specifications subject to change without notice.

Unit Specifications

General

TM

Features Benefits

Included Accessories

DSC (Digital Selective Calling) Compliant with the latest FCC specifications for Class-D VHF Radios. Digital Selective Calling 

allows you to send a distress signal at the touch of a button or exchange position information 

with other boats or stations. DSC features on this Class-D radio include; A Dedicated Channel 70 

(DSC Channel) Receiver, GPS Position Display Capability, Illuminated Distress Button, Easy MMSI 

Entry, Position Send and Request, Position Input Reminder, Coast Guard DSC Check Capability, etc.

1 or 25 Watts Dual output power for short and long communication.

U.S.A., Canada & International Channels Allows operation on any of the three (3) different channel maps established for these areas.

Rewind-Say-Again® Replay missed calls. Automatically records the last 20 seconds of incoming radio transmissions. 

Handy when in noisy conditions.

10 NOAA Weather Channels Instant access to national all hazards and weather information, 24 hours a day.

Weather Alert Alerts with an audible tone and visual alarm if threatening weather is nearby.

Automatic Radio Check Checks battery voltage when transmitting, RF power output, and antenna output. 

Instant Channel 16/9 Instant access to channel 16 and channel 9 for emergency situations.

GPS Inside Simply connect the radio to power and the radio will know your location. You can send your 

position information in case of emergency, or exchange position information with other boats. 

Tri-Watch Monitors three (3) channels at once – Channel 16, Channel 9 and one (1) user selected channel.

Scan / Memory Scan Scan all channels to find conversations in progress, or scan channels placed into memory.

Channel Names Friendly VHF channel names under the channel number.

Signal Strength Meter Shows the strength of incoming signal.

Illuminated Keys Allows high visibility of keys.

Illuminated LCD Display: Super Large See radio settings from practically anywhere with the largest LCD available on a fixed radio.

Noise Canceling Microphone Blocks background noise. 

External Speaker and PA Speaker Connect an external speaker and a PA (Public Address) speaker.

NMEA In and Out NMEA in for GPS input. NMEA output to display other vessels and their information transmitted 

by DSC on your chartplotter. 

Submersible Meets JIS8 standards; Submersible for 30 minutes in one meter deep water.

External Alarm Input Senses the alarm from your chartplotter and uses the speaker on the radio to amplify the alam 

for waypoint arrival, MOB, etc.

3 Year Warranty (on radio) For products sold in the U.S.A.

Flush Mount Kit & Surface Mount Kit Easy installation of radio in or on almost any flat surface with supplied hardware.

NMEA Input Cable Allows input from NMEA 0183 devices. 

CHANNEL

VOLUME

SQUELCH

OFF

DISTRESS

DISTRESS

REWIND

HI/LO MENU 16+ SUBMERSIBLE