Organization Name:

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

Requestor Representative:

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.

3.

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

4.

*

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/

7.

5. Requestor's relationship to the product:

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

Please indicate whether any additional attachment contains business confidential information 

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

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1
8. Is this product, or a comparable product, available from sources in the United States? (If you

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

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:

2016 Value:

2015 Value:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).




Exhibit A








Exhibit B


Exhibit C
Michael J. Soley Jr.

President and CEO

Miller-Bradford & Risberg, Inc.

W250N6851 HWY 164

Sussex, WI 53089

262.246.5710

msoleyjr@miller-bradford.com

July 27, 2018

Mr. David Dennison

Manager, Marketing Services

BOMAG Americas, Inc.

125 Blue Granite Parkway

Ridgeway, SC 29130

Dear Mr. David Dennison:

I am a life-long resident of the State of Wisconsin and have worked in our family owned 

construction equipment dealership, Miller-Bradford & Risberg, Inc. my entire adult life. Our 

company represents several large and many small construction equipment OEM’s in a territory that 

covers Northern Illinois, the entire State of Wisconsin and the Upper Peninsula of Michigan. We 

have seven strategically located dealerships in that geographic footprint which I travel to regularly. 

To say I have experience and knowledge of transportation infrastructure in this part of America is an 

understatement. The condition of the roads has been poor for many years and is frankly worsening 

which leads me to pen this letter.

Most of the OEM’s we represent, BOMAG included, build machinery that is designed to construct, 

repair and maintain the very infrastructure I drive on daily. This equipment is used by contractors 

and local units of government to build and maintain highways as well as our local roads and bridges. 

Placing a tariff on this equipment will only increase the cost contractors and municipal agencies 

must pay and reduce the amount of money that can be spent to rebuild transportation 

infrastructure in our part of America. This doesn’t seem like a logical choice to me, but I am not 

living inside the beltway.

Wisconsin has several key drivers to its economy including agriculture (especially dairy), 

manufacturing, forestry and tourism. These industries are often in rural area that are constantly 

fighting budget constraints. Why is this important? These industries require strong roads due to 

the heavy loads and volume they place on them. They are vital industries to our rural areas and 

need to be supported if they are to survive. 
Mr. David Dennison

July 27, 2018

Page 2

4843-8841-9951.1

BOMAG builds asphalt recyclers that are used to grind up an old county highway or local road, so it 

can be used to provide a stronger and longer lasting road base for the new layer of asphalt that will 

placed upon it. Yes, the asphalt will be placed by a BOMAG asphalt paver and compacted by 

BOMAG rollers to provide a smooth and strong road that will last for years, if not decades to come. 

Driving up the cost of this equipment by tariff will only reduce the amount of construction and/or 

rehabilitation that can be completed on todays’ deteriorating infrastructure due the already tight 

budgets state and local units of government are facing.

I have copied three Congressman from Wisconsin that understand infrastructure investment creates 

a platform for GDP growth and jobs. I hope they echo my feeling that placing tariffs on construction 

equipment and its supply chain only drives up costs on items the government itself funds (aka

roads) is not intelligent.

Sincerely,

Michael J. Soley Jr.

President and CEO 

Miller-Bradford & Risberg, Inc.

Cc: Congressman Sean Duffy

Congressman Mike Gallagher

Congressman Glenn Grothman