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 

informationinthefollowingfieldsandexplainthebasisandrationaleforyourstatements. 

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

correct to the best of your knowledge.

1. Indicatewhetherthe 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:

*Usenumerical characters onlywith no special characters (example: 1023456789).Forhelpinfinding 

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

8525.60.1030

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. Pleaseindicatewhetheranyadditionalattachment containsbusiness confidential 

information (BCI), is a public document, oris 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 HH600 FLT GPS BT (in black and white variations), which is a 6-

watt, hand-held marine with Bluetooth connectivity to a smartphone and GPS. The unit is composed of 

plastic, steel, aluminum and electronic components. Detailed product specifications, including 

dimensions, are attached.

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 fromsources intheUnitedStates?:

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

10. Pleaseprovide thevalue andquantity (withunits) oftheChinese-originproductof concern 

thatyoupurchasedforeachcalendaryearspecified.Limitthis figuretotheproducts 

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 

provided in Section Bofthe Federal Register notice (note:text entered below can extend 

beyond the apparent size of this 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

These products are labeled and invoiced as VHF marine radios. Thus, they are easily distinguishable 

among products in this 8-digit classification. 
Built-In GPS Receiver & DSC

Shows GPS coordinates on screen and 

automatically sends GPS location with 

DSC calls. 

Bluetooth® Wireless Technology

Make and receive phone calls using 

Bluetooth® Wireless Technology, keeping 

your cell phone safe and dry.

FLOATING

Never lose your radio. Floating design and 

orange core make retrieving the radio easy 

if dropped overboard.

Rewind-Say-Again®

Replay missed VHF calls.

6 Watt VHF

Select between 1, 3 and 6 Watts for short 

and long range communication.

Flashlight/S.O.S. Light

The radio’s light can be used as a flashlight 

or S.O.S. signal, and the light flashes automatically when dropped in the water.
Cobra®, CobraMarine®, Nothing Comes Close to a Cobra®, MicroBlue® ,Rewind-Say-Again®, and the snake design are registered trademarks of 

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

The Bluetooth® word mark and logos are registered trademarks owned by Bluetooth SIG, Inc. and any use of such marks by Cobra Electronics 

Corporation is under license. Other trademarks and trade names are those of their respective owners.

©2017 Cobra Electronics Corporation, 6500 West Cortland Street, Chicago, IL 60707, USA

MRHH600 SP 12/16 Nothing Comes Close to a Cobra®

Features Benefits

Included Accessories

Built-In GPS Receiver Shows GPS coordinates on screen and automatically sends GPS location with DSC calls.

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 Input Reminder, Coast Guard DSC Check Capability.

Bluetooth® Wireless Technology Make and receive phone calls using Bluetooth® Wireless Technology, keeping your cell phone 

safe and dry. Now includes voice dialing and Caller ID.

FLOATING Never lose your radio. Floating design and orange core makes retrieving radio easy if 

dropped overboard.

Rewind-Say-Again® Replay missed VHF calls.

6 Watt VHF Select between 1, 3 and 6 Watts for short and long range communication.

Flashlight/S.O.S. Light The radio’s light can be used as a flashlight or S.O.S. signal, and the light flashes when dropped 

in the water.

Submersible Meets JIS8 (IPX8) standards; submerible for 30 minutes in more than one meter 

deep water.

All 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.

MOB (Man Over Board) Dedicated MOB key marks and memorizes position information if a crew member falls overboard.

Noise-Canceling Microphone Blocks background noise for clearer conversations.

Basic Navigation Basic navigation features include digital compass, waypoint navigation, course, speed, etc. 

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

BURP Vibrates water out of the speaker grill and improves speaker performance.

External Speaker/ Microphone Jack Connect Cobra speaker mic accessories for hip or body worn operation.

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

NMEA Out NMEA 0183 outout to display other vessels and their information transmitted by DSC on 

your chartplotter.

Unlimited Memory Channels Allows programming of unlimited channels for easy retrieval or scanning. 

Tri-Watch Scans three channels - channels 16, 09 plus one working channel.

Channel Names Friendly VHF channel names under the channel number. 

Scan Scan all channels to find conversations in progress.

Memory Scan Scan channels programmed in memory to find conversations in progress.

Signal Strength Meter Shows the strength of the receiving and transmitting signal.

Button/Key Lock Locks function buttons/keys to eliminate accidental change of settings.

Battery With Charge Contacts Allows charging of batteries in unit.

Illuminated Function Keys Allows high visibility of function keys. 

Selectable Key Tone Beep Key tone press beeps can be turned off for silent operation. 

Large, Illuminated LCD Display Allows high visibility of display. 

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

CM 110-034 2000mAh LiON Polymer Rechargeable Battery (black color).

CM 110-032 Desktop Charging Cradle.

CM 110-035 Alkaline battery tray. Use with AA Alkaline Batteries.

CM 120-007 AC Adapter with North America Plug.

CM 130-005 12V DC Accessory Plug.

CM 140-003 NMEA Output Cable.

CM 300-002 Replacement Antenna (black color).

CM 240-003 Spring-Loaded Belt Clip.

Optional Accessories

CM 330-001 Lapel speaker/mic.

CM 110-034 Replacement or back-up 2000 mAh LiON Polymer Rechargeable Battery (black color).

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

International

10 NOAA Weather Channels

Channel Spacing 25 kHZ

Modulation 5 kHz Max.

Input Voltage 7.4 VDC

Battery Life: 5% TX, 5% RX, 90% Standby

10 Hours @ 6 Watts

Battery Requirements Cobra Battery Pack

CM 110-034

Current Drain:

 Stand-by 45 mA

 Receive 200 mA

 Transmit 1.8 A @ 6W High Power

700 mA @ 1W Low Power

Temperature Range -20oC to 50oC

Unit Dimensions 5.71” H x 2.83” W x 1.87” D

(not including antenna)

(131 mm x 72 mm x 

47 mm)

Unit Weight (Lbs) 0 lb., 11.60 oz. (329 g.) 

with Lithium-Ion Battery

Receiver

Frequency Range 156.050 to 163.275 MHz

Receiver Type Double Conversion 

Super-Heterodyne

Sensitivity: -120dBm - 12 dB SINAD

Adjacent Channel Selectivity -60

Intermodulation and Rejection -70

Spurious & Image Rejection -60

AF Output 250mW @ 8 Ohms

Transmitter

Frequency Range 156.025 to 157.425 MHz

RF Output Power 1, 3 or 6 Watts

Spurious Emissions -60 dB @ High Power

-55 dB @ Low Power

Frequency Stability +/-5 ppm

FM Hum & Noise 40 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: -148dBm, 

 

GPS receiver tracking sensitivity Nominal: -165dBm, 

 

Differential System Compatibility WAAS (United States), 

EGNOS (Europe), 

MSAS (Japan), 

NMEA Info:

Output Specification NMEA 0183- ASCII serial output

Electrical Standard EIA-422

NMEA Sentences GGA, GLL, GSA, GSV, 

RMC, VTG, ZDA

Packaging Specifications

Individual Clam/ 10.47” H x 8.46” W x 3.35” D

Box Dimensions (266 mm x 215 mm x 

85.09 mm)

Individual Clam/Box Weight 2.575 lbs. (1,168 g.)

Master Pack Qty. 2

Master Pack Dimensions 12.31” H x 7.44” W x 8.19” D

(312.6 mm x 189 mm x 

480.06 mm)

Master Pack Weight 6.043 lbs. (2,741 g.)

SKU # MRHH600WFLTGPSBT

UPC # 0 28377 20200 1

Master Pack Barcode 5 0028377 20200 6

Classification Class 2

Version 4.1

Range 10 Meters

Specifications subject to change without notice.

Unit Specifications

General

Bluetooth®