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: Needle roller bearings (SUJ2 steel) consisting of inner and outer rings, a 

cage or retainer, a seal, and steel needle rollers that do not exceed 5mm in 

diameter and are at least three times the diameter in length. (HTS# 8482.40.0000)

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 9-month implementation 

delivery cycle, given the safety critical applications related to its automotive end use. These 

NSK bearings are designed to produce the desired motion and reduce friction between moving 

other components to provide maximum reliability, durability, and performance in its respective 
automotive end use. As a result, quickly changing production locations is not a viable option. 

Because these NSK bearings are considered a safety critical application of a vehicle, any

premature or forced change in design, material, or process (including new source or location) 

without adequate planning could have severe ramifications to the performance of a vehicle. 

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

competitiveness. Because NSK does not have a significant amount of business in the US for the 

subject needle roller bearings, it does not make sense for us to localize production within North 

America at this time. As a result, the best cost structure for our customers is based on globally 

consolidated production in China. This required NSK's automotive business to find overseas 

plants to support the higher volumes and unique production requirements of our automotive

customers within this complicated business segment. 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 of vehicles) which will eventually hurt the ultimate end user -

the individual consumer.

We are also not aware of any impact the production of the subject bearing rings 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, along with their respective 

sub components, have 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# 8482.40.0000, which is produced and sourced from China.

Sincerely,

Steven A. Beckman

NSK Americas, Inc. 

Chief Executive Officer 

beckmas@nsk-corp.com

(734) 913-7500