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.

(Contains BCI

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

Flow Ratchet & Shaft Casting. Please see part specification below.
Overall Length: 11.328 in

Inner Diameter: 1.291 in

Threading: | in NPTF x | in NPTF

Material: Aluminum 356-T6

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/

8479909496

4. Requestor Information

Requestor Name (Last, First): [Anway, Karl

Organization Name: [Reelcraft Industries

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.gov include additional attachments?

INO

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 1 CONTINUED BELOW


8. Is this product, or a comparable product, available from sources in the United States?:

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

INO

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: 2017 Quantity:
2016 Value: 2016 Quantity:
2015 Value: 2015 Quantity:

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).

1. This product is only available from the existing source in China, an American-owned company operating in
China which sells to Asian markets while also trading parts with its sister company in the United States. The
design for this product is specific to the individual Bill of Materials of reels manufactured in America. It is not

mass produced or readily available, and is in fact only traded through intra-company sales.

This product also requires tooling which represents a substantial cost, and would require several months

worth of design and manufacturing before a domestic source could be obtained.

2. The imposition of additional duties on this product would cause severe economic harm to Reelcraft
Industries. An increase in duties essentially amounts to an increase in costs, which will impact our employees,
customers, and community. This reduces our ability to increase wages for American workers, as well as
provide the outstanding benefits that allow them to prosper and grow within the local community, boosting

the local economy, and help to keep America the prosperous nation it is today.

The increase in costs risks the possibility of a reduction in workers, a reduction in workers’ pay and benefits,
lor an increase in prices which would prompt customers to favor foreign competitors and become a loss for the

(American economy at large.

3. This product is not related to “Made in China 2025” or other Chinese industrial programs to the best of our
knowledge. This is a low-technology industrial component which represents no strategically important

leconomic factor for our current trade relations.

VERSION 1 END


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