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October 4, 2018

The Honorable Robert Lighthizer

U.S. Trade Representative

Office of U.S. Trade Representative 

600 17th Street, NW

Washington, D.C. 20508

Attn: William L. Busis, Chair of Section 301 Committee 

Re: Docket No. USTR-2018-0025

See: Attached Exclusion Request for HTS Item 9032.10.0060 Subject to Section 301

Tariffs

Dear Ambassador Lighthizer:

In order to further address formatting issues discussed with the USTR help desk, the 

Stanley submission is being re-filed electronically as of October 4, 2018.

This firm represents Stanley Electric Co., LTD, Stanley Electric U.S. Co., Inc., II 

Stanley, Co., Inc., and Stanley Electric Sales of America, Inc. (collectively "Stanley"). Stanley 

respectfully submits this exclusion request regarding the proposal to impose 25 percent tariffs on 

United States imports from China identified in Annex A as part of the Section 301 investigation. 

Specifically, Stanley requests the following item be excluded: 9032.10.0060.

Stanley originally submitted an exclusion request on August 8, 2018, which included all 

of Stanley's products effected by 25 percent tariffs identified in Annex A. Stanley purposefully 

submitted all of Stanley's effected products in one request because the products are assembled 

and integrated to create lights and other related electric equipment for automotive manufactures. 

On August 14, 2018, USTR requested that Stanley submit separate exclusion requests for each 

HTS code. Stanley now submits it's individual exclusion request forms. Stanley respectfully 

requests USTR to consider the effects of the 25 percent tariffs on Stanley overall.

Background

Stanley is a worldwide company, based in Tokyo, Japan, providing automotive lighting 

equipment and electronic components to automotive manufacturers. Stanley employs 

approximately 2,400 employees in the United States: London, Ohio; Battle Creek, Michigan; and 

Irvine, California. Stanley employs a total of 16,687 worldwide. Stanley's U.S. branches supply 

materials to several automotive companies in the United States including: General Motors, 
October 4, 2018

Page 2

Toyota, Honda, Nissan, Subaru, and other Tier 1 automobile manufacturers. Stanley uses a 

combination of products in order to create the lighting and electric equipment it sells to 

automotive manufacture's in the United States.

Conclusion

Stanley believes the tariffs on the above listed item will cause disproportionate 

economic harm to U.S. interests, especially the U.S. worker and consumer. [***]. Stanley

respectfully requests that the USTR take into consideration the substantial economic harm to 

American workers that the tariffs will likely produce and exclude the above listed item.

Exclusion Request Procedures

Stanley's submission contains business confidential information for which Stanley 

requests confidential treatment. Stanley has identified business confidential information in 

brackets and has stamped each page containing business confidential information "BUSINESS 

CONFIDENTIAL." A public version of the request is also provided. Stanley hereby certifies that 

disclosure of the bracketed business confidential information would endanger trade secrets or 

profitability, and that information would not customarily be released to the public. Stanley 

certifies that the information provided is complete and correct to the best of Stanley's knowledge.

Should you have any questions or require additional information, please do not hesitate to 

contact me. 

Very truly yours,

VARNUM

Dennis M. Devaney

DMD/rmf

14076935_1.docx
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. 

Public Document 

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

Heater control unit: air conditioning for cabin temperature. 

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/ 

9032.10.0060 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Huberty, James 

Stanley Electric Co., LTD et. al 

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

Requestor Representative: Dennis M. Devaney & Dena H. Shuayto 

5. Requestor's relationship to the product: Importer 

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

YES 

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. 

Public Document 

VERSION 1 CONTINUED BELOW 1 

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

NO 

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

NO 

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: [Icicle] 2017 Quantity: [Icicle] 

2016 Value: [Icicle] 2016 Quantity: [Icicle] 

2015 Value: [Icicle] 2015 Quantity: [Icicle] 

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). 

The proposed tariffs effect 77 items manufactured by Stanley, including item 9032.10.0060, 

purchased regularly from China by Stanley's Ohio, Michigan and California branches. Due to the 

substantial cost increase, Stanley may be forced to lay-off a number of U.S. employees and/or cut 

employee benefits to keep prices competitive. Stanley must also consider whether it will be more 

economical to move production of some of these items to other facilities, such as Mexico. Stanley 

currently has no sources other than China for purchasing item 9032.10.0060. Stanley going forward 

could address sourcing by creating additional U.S. operations if the exclusion request is granted. 

The United States overall trading relationship with China is fundamentally important to Stanley, 

which relies substantially on products manufactured in China to stay competitive in the modern world 

economy. Stanley understands the U.S. government's goal of addressing unlawful, discriminatory and 

burdensome trade practices of the Chinese government, however the selected items will take a 

significant toll on Stanley and the U.S. automotive industry. An additional 25 percent tariff on several 

of the products Stanley uses and then sells, such as item 9032.10.0060, will force Stanley to increase 

prices, and in turn, negatively affect the U.S. automotive industry and economy. Specifically, the 

tariffs will: put the business at a disadvantage relative to their competitors in other nations who can 

continue importing critical components from China at a fraction of the cost; increase the costs of 

automotive products used by the U.S. consumer; and raise the cost of living for most Americans, 

particularly given retaliatory tariffs imposed by China. Furthermore, this product is not related or 

relevant to Made in China 2025 or any other Chinese industrial programs that we are aware of. 

Stanley certifies that the information provided is complete and correct to the best of Stanley's 

knowledge. 

VERSION 1 <C; END 2 .

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