Public Document 

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

Household Vacuum Sealing appliance 1\4odel V100 Series Ziploe Vacuum Sealer. The appliance draws a 

vacuum in, and seals, plastic film bags for the purposes of vacuum sealing and protecting food and other 

household items from spoilage. The appliance consists of a plastic, body, power source, controls, control 

buttons, heating element and sealing device. See Schedule A to Attachment for graphic and detailed 

description. 

3, 10-digit HTSUS item number* for product you wish to address in this pr duct exclusion request: 

*Use numerical characters only with no special characters (example: I 23456789). For help in finding 

the HTSUS item number associated with your product, see 1/V- ps://hts.usitc.gov! 

8422.30.91.91 

4. Requester Information 

Requestor Name (Last, First) 

Organization Name: ICTI Industries Corporation 

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

Requestor Representative: N/A 

5. Requestor`s relationship to the product: Importer 

6. Does this submission in regulations.govinclude additional attachments? 

YES 

7. Please indicate whether any additional attachment contains business confidential 

information (BCD, is a public document, or is a public version of a BCI document. 

. ublic Document 

VERSION I CONTINUED BELOW 

-e hen 1\4. Merrick 
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: 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). 

See Attachment 

We anticipate import of at least 34,000 units in 2018 at a value of $540,000 

VERSION J. EN) 2 
Via online submission at regulations.gov, docket number USTR-2018-0025 

PUBLIC DOCUMENT 

September 19, 2018 

The lionorable Robert E. Lightizer 

U.S. Trade Representative 

Office of the United States Trade Representative 

600 17thStreet, NW 

Washington, DC 20006 

Re: USTR-2018-0025 — Request for Exchision of Particular Products from the 

Determination of Action Pursuant to Section 301: China's Acts, Policies, and 

Practices Related to Technology Transfer, Intellectual Propery and Innovation 

Dear Ambassador Lightizer: 

CTI Industries Corporation ( crI)is a manufacturer of various flexible film products based in 

Lake Barrington, Illinois, in the Chicago Metropolitan area, including foil balloon products, 

vacuum sealing bags, packaging films and films for other commercial purposes. One of our 

principal lines of products that we manufacture is rolls of film and pouches which are utilized with 

vacuum sealing machines for the household. When the pouches are vacuum sealed, they protect 

and preserve food products in the home, whether in the refrigerator or on the counter, for extended 

periods. 

In 2012, we introduced in the United States a vacuum sealing line of products including small 

rnachine appliances which vacuum and seal film bags, together with the rolls of film and bags for 

use with these machines. The vacuum sealing appliances are intended to enhance market presence 

and related sales of U.S. manufactured bags and rolls of film. We market these products in the 

United States, Mexico and Canada under the brand and mark Ziploc® Brand Vacuum Sealing 

System, under license from S.C. Johnson & Son. The vacuum machine appliance are 

manufactured for us in China. 

CTI INDUSTRIES CORPORATION 22160 N. Pepper Road Barrington, IL 60010 (847) 382-1000 Fax (847) 382-1219 
We submit this statement in support of our request to exclude our V100 Vacuum Sealer Appliance 

imported under HTS 8422.30.91.91, from the tariffs applicable to products classified within the 

8422.30.91 HTS subheading under the Notice of Action published by the Office of the U.S. Trade 

Representative ("USTR") on June 20, 2018 (the "Notice of Actioe). 

As discussed below, subjecting this home vacuum machine appliance to tariffs would cause severe 

economic harm to our company and significant additional cost to the consumer in the Unfted States 

— without advancing any of the objectives of the China 301 Determination. 

1. Exclusion of Home Vacuum Sealing Appliance 

The product for which CTI is seeking an exclusion from the tariffs is classified within the 

8422.30.91 HTS subheadin.g which is identified as -- Machinery for filling, closing, sealing or 

labeling bottles, cans, boxes, bags or other containers; machinery -for capsuling bottlesjars, tubes 

and similar containers; machinery; machiner for aeratin bevera es — Other. Home vacuum 

sealing appliances are readily identifiable and distinguis.hable from other products within the 

applicable 8-digit HTS subheading and are classified, specifically, under a 10-digit HTS 

stibheading 8422.30,91,91. U.S. Customs has recent experience identifying and classifying 

vacuum sealing appliances. In 2012 CBP tariff ruling, vacuum sealing appliances for the sealing 

of bags to store food. products were classified under the subheading HTS 8422.30.91.91. CBP 

Tariff Ruling N210195 (April 13, 2012), available at https:rulings.cbp.goviru1ingiN210195. CTI 

currently imports two models of its vacuum sealing appliance meeting this general description and 

under this HTS subheading. This request for exclusion is with respect to th.e V100 Series Model. 

A specific graphic representation and description of the model is attached as Schedule A. ("CTI 

Vacuum Sealing Appliance"). A separate request is submitted for CTI's other model. 

The CTI Vacuum Sealing Appliance is currently imported and sold by CTI to major retail chains 

in the United States. There is no assurance that CTI will be able to increase its prices for these 

appliances to its current or prospective customers to cover the added costs of the tariffs imposed. 

Without a significant price increase to its customers, the effect of the tariffs would be to make the 

CTI Vacuum Scaling Appliances unprofitable to CT1. CTI would be incurring a loss on all of the 

units sold, and rnay be forced to cease its vacuum sealing business entirely, as well as its U.S. 

manufacture of bags and rolls of film for use with these appliances. If CTI is able to raise its prices 

to its customers, this will result in increased retail prices to consumers, which will resuh in 

increased cost to consumer and, most likely, reduced sales of the products. 

Alternative sources of supply for comparable appliances are not immediately available to CTI. 

2. About CFI and Home Vacuum Sealing Appliances 

2 

CTI ENDUSTRals CORPORATION 22 60 N. ° -,Tor Road. Barrington, II- 60010 (847) 3S2- 000 - 847) 3S")-12 9 
CTI was founded in I 976 and has conducted its business in Lake Barrington, Illinois, a suburb of 

Chicago. Illinois since that time. Since inception, the focus of the company has been on the 

development, production and sale of flexible filin products for packaging and consumer uses. 

During the entire period of its existence, CTI has produced, and to this day does produce, the vast 

tnajority of its products at its principal plant located in Lake Barrington. 

Initially, CTI produced flexible filrn pouches for the packaging of liquid products such as milk, 

battery acid, wine, ketchup and the like. In 1978, CT1 became one of the first companies to produce 

foil balloons (plastic balloons often with a metalized coating and printed graphics) which remain 

buoyant for extended periods of time when filled with helium. 

CTI was engaged in the development of plastic storage bags which earne to be kn.own as Space 

Bags® and in 2005, began the development and production. of multi-layered bags and pouches for 

the vacuum sealing of food and household items. CTI developed a line of zippered bags containing 

a valve to remove air, for the storage of food and household items. Shortly, thereafter, the 

Company began to develop multi-layer bags (and rolls of fihn which could be converted to bags) 

for use with vacuurn sealing appliances, and began to market these products to various retail chains 

and outlets. 

In 2012, CT1 determined to develop and mark.etan entire line of vacuum sealing appliances, with 

bags and rolls of film for use with the appliances, and obtained a license from. S.C. Johnson & Co. 

to market these products un.der the Ziploc® Brand.. 

Working with a supplier in China, CTI and the supplier developed several designs for vacuum 

sealing appliances. CTI determined at the time that the only source from which it could obtain 

these vacuum sealing devices at a commercially viable cost was China. There was then, and now, 

to CTIl's knowledge no supplier in the United States or other country who could develop, engineer 

and supply these appliances at a cost to CTI which would be commercially competitive and 

marketable in the United States. 

CTI's Ziploc® Brand Vacuum Sealing System was introduced in March 2012. Over the past six 

years, the product line has gained acceptance in several major retail chains and is also sold on-line 

by CTI and through Ama7on. Sales in the line (including the appliances, and the bags and rolls of 

film CTI manufactures in the United States) have reached as high as 517 million on an annual 

basis and has enabled CTI to increase its domesticmanufacturing of bags and rolls of fiIm 

substantially. This year, we have just introduced the V110 Series model (the subject of this 

request). First shipments of the product have arrived in the United States and have been subjected 

to the 25% tariff. 

3 

CTI INTYUSTRIES -;ORPORATION 22 160 N. Pe! _,arrington, IL 60010 (847) 382- ICOO Fax (847) 3 ,)-1'7) I 9 
We had expected sales of the CTI Vacuum Sealing Appliance to support substantial increases in 

our production of bags and rolls of fih-n in the U.S. Without these sales, or with reduced sales, we 

expect our production of bags and rolls of filin in the U.S. to decline or stop entirely. 

CTI's marOns on the vacuum sealing appliances have been low. With the application of the 25% 

tariff, CTI will incur a substantial loss on every appliance which it irnports and sells at the prices 

in place with its customers. Even if CTI obtains some pricing relief from some of its customers, 

CTI's margins will be severely reduced and sales volumes are likely to be considerably less than 

anticipated. 

3. China is the only economically viable source for CTI's Vacuum Sealing 

Appliances. 

The products involved are small, relatively Mexpensive appliances, for home use to vacuum seal 

and store principally food items. To CTI's knowledge, there are no United States sources for these 

appliances and our research indicates that it is not possible to produce these items in the United 

States at cost levels which would permit sale to consurners at acceptable levels. 

There are manufacturers of vacuum sealing machines in Europe and but these are machines 

produced at substantially hither cost and sale prices, and are generally for commercial use or very 

high end consumer use. Comparable small vacuum sealing appliances are not available from these 

producers. 

The vacuum sealing appliances made in China for CTI are made to design and specifications 

jointly developed by CTI and our China supplier. No comparable machine is made by any source 

other than in China. 

CTI' s only possible alternative to China would be to set up a production facility in some other low 

cost country. However, this is not a practical solution for CTI as this alternative would require a 

substantial investment in plant, equipment, personnel and training, would take a number of months 

to implement and may well not result in the production of an appliance at a cost which would be 

economically acceptable. CTI does not have the financial resources even to attempt this 

alternative. 

Tariffs on Home Vacuum Sealer Appliances would cause severe economic 

harm to CTI, in the marketplace and to consumers. 

Imposition of a 25% tariff on CTI for its small home vacuum sealing appliances will have, and is 

now having, devastating consequences to CTI. CTI's pricintt to its retail custorners is already 

established, and there can be no assurance that CTI will be able to sell the appliances to its 

4 

1ES CORPORATION 2 al ']\-L Pepper Road Barrington, IL 60010 (S47) 382-1000 Fax (

.847) 38i-1219 
customers at prices incorporating all, or any part, of the tariff cost. At the present, with the tariff 

imposed and no price relief from customers, CTI is incurring a substantial loss on every appliance 

it sells. 

Even if CFI obtains some pricing adjustment with some of its customers, CTI's already low 

margins on the CTI Vacuum Sealing Appliance will be further reduced, retail prices will increase, 

customers who do purchase will have to pay rnore and sales volume is likely to decline. 

Without immediate relief from the 25% tariff cost, CTI may be forced to terminate, or significantly 

reduce, importing these appliances and to terminate its vacuum sealing business entirely. CTI's 

U.S. production of products will be severely impacted since CTI now produces in. the U.S. all of 

the bags and rolls of film for use with the appliances. If CTI is forced to cease, or substantially 

reduce, importing and selling the appliances it is likely that CTI' s production in the U.S. of bags 

and rolls will also have to cease. 

Over the past three years, sales of vacuum sealing appliances and associated bags and rolls have 

represented a total of $38.5 million or about 21% a CTI s total sales. Loss of this revenue, on a 

profitable basis, would constitute a substantial threat to CTI's continued business overall and to 

the U.S. employment of 300 individuals. 

Imposition of the tariff will also have a substantial deleterious effect on retail stores and consurners. 

In all probability, small vacuum sealing appliances simply will not be available, and consumers, if 

they are able to obtain these appliances at all, will have to purchase much more expensive or 

commercial models. 

For retailers, the small vacuum sealing appliances will not be available for sale. Or, retailers will 

be :forced to pay significantly more to purchase the appliances and will have to raise prices to 

consumers. 

Such damage to CTI, to retailers and to consumers is totally at odds with the purpose and intent of 

the China 301 Determination by the USTR. 

5. Application a tariffs to small vacuum sealing appliances is inconsistent with 

the Administration's policy goals. 

Application of the proposed tariffs to CTI's small vacuum sealing appliances is inconsistent with 

the stated purpose of the Notice of Action, which was to impose higher tariffs on "goods imported 

from China containing industrially significant technology, including those related to the "Made in 

China 2025 prograrn." CTI's vacuum sealing appliances are small, relatively simple devices and 

5 

CTI UIUSTiE5 CORPO' _T 22160 N. Pepper Road B9.rrington, IL 60010 047) 382- 000 Fax ($47) 38?-3219 
certainly do not represent technology that confers an advantage on China, and are alrnost certainly 

not the focus of Chinese industrial policy_ 

It is possible that the broad 8-digit FITS category — 8422.30.91 - on the USTR's list, may include 

products which do fall within the purposes of the Notice of Action. However, the subcategory 

cornprising HTS 8422.30.91.91, which specifically includes vacuum sealing appliances, represents 

only small portion of that broader 8-digit category. Clearly, this small subcategory does not 

include iterns which were intended to be covered by the Notice of Action. 

6. The proposed exclusion would be easily administrable by C. 

CTI is requesting the exclusion of an easily distinguishable subset of products covered by the 

broader HTS 8422.30.91 subheading. The aggregate value of all products imported from China 

under this 8-digit subheading in 2017 was approximately $160 million. In that same year, the total 

value of all CTI Vacuum Sealing Appliances imported from China was approximately $2,150,000. 

The de minimus nature of CTI's vacuum sealing appliance imports from China relative to the 

broader subheading means that the requested exclusion cannot underrnine USTR's goals and 

actions with respect to the China 301 Determination. We believe U.S. Customs and Border 

Protection ("CBP") will be able easily to administer an exclusion for CTI's Vacuum Sealing 

Applian.ces because CIT s products are imported exclusively under the narrowly-defined 1.0-Digit 

HITS 8422.30,91.91 subheading. CTI is also willing to work directly with CBP to identify its 

product in terms of its specific physical characteristics and markings if that would be helpful. 

On all import documents and all packaging, CTFs Vacuum Sealing Appliance is clearly identified, 

in fact, as vacuum sealing devices. Identification of these products in the customs process will be 

immediate, simple and clear. 

7. Request for exclusion of CTI vacuum sealing appliances from tariffs. 

CTI has invested substantial resources in order to develop and design vacuum sealing appliances, 

and associated bags and rolls of film in the United States and has succeeded in becoming a 

substantial participant in the U.S. market. We have created millions in economic value in the 

process and have grown to support hundreds ofjobs in the United States for the production of the 

filrn products which are integral to the vacuum sealing system. Imposing tariffs on CTI's Vacuum 

Sealing Appliance would seriously undermine CTI's success in supporting American economic 

employment growth. 

For all of the reasons set forth above, CTI respectfully requests that USTR exclude CTF s Vacuum 

Sealing Appliance imported under HTS classification 8422.30,91.91 from the list of products 

6 

CTI INDUSTRIES MRPORATION 22160 N. Pepper Road Barrington, 11, 60010 (847) 382-1000 Fax (847) 382-1219 
subject to tariffs in cormection with the Notice of Action. We also respectfully request refund to 

CTI of tariffs already paid for items which have been imported since imposition of the tariffs. 

Thank you for your consideration. For any questions regarding this request, please contact Stephen 

M. Merrick, Chief Executive Officer at 847.620.1308. 

7 

CFI INDUSTRIES 1..:0 RPORATION 12160 N. Pepper Road .irir 1L6001 ( 47) 382-1000 Fax (g47) 382-17.19 
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CTI Industries Corporation 

100 Series Vacuum Sealer Machines S.147 0 2 of 4 

Machine Specifications 

Machine Series 

Model No 

Product Description 

Market 

Model No 

Revision 

Issue Date 

Product Design 

Feature List 

Housing 

Press Bar 

Seal Gasket (Upper) 

Seal Gasket (Lower) 

Heating Element 

Vacuum Pump 

Protection 

Vacuum & Sel 

Seal 

Indicator 

Brand Logi) 

Feet 

Power Cord' 

Plug ... . 

Cord Storage 

Lid Locking 

100 

V110 

Vacuum Sealer 

US 

V110 

0 

04/11/2018 

ABS 

Silicone Rubber 

CR Rubber 

EVA 

OCr25A15, 3mm width 

-50KPa 

Microswitch Interlock, Heater Thermal-fuse 

Tact Switch 

Tact'Switch 

Dual Color (Red / Green) 

Silkscreen 

Silicone Rubber 

SPT2, 18AWG, 2C, 60degC, UL Polarized Plug, 0.69m exposed (not 

include the plug) 

NEMA plug 

N/A 

Mechanical Latches 

Colors 

Housing White 

Bottom Cover Gray 

Silkscreen Gray 
CTI Industries Corporation 

100 Series Vacuum Sealer Machines S.147 0 3 of 4 

Inlay Matte Finishing 

Press Bar Black 

Seal Gasket Black 

Rubber Feet Gray 

Power Cord & Plug Gray 

Warnings / Artwork 

CAUTION HOT 

Do Not Store in The Latched Position 

Rating Mark 

Packaging info 

Retail Carton (1._ x W x H) / mm 326 X 124 X 75 

Master Carton (L x W x H) / mm 341 X 163 X 144 

Qty per Master carton: 2 

Packaging Details 

Master Carton 

Gift Box 

insert Card 

Polybag 

Instruction Manual 

Registration Card 

2 Pint Bags 

Technical Specification 

Dimension (1_ x W x FI) / mm 302 x 98 x 51 

Net Weight / kg 0,75 

Bag Width / mm 203.2 (8") 

Program Operation Vacuum & Seal, Seal 

Voltage 120VAC 
• . ... • 

.. 

.. ..... ....... 

UL 963 .::::....... . . ... .... 

.....-• • 

-..:-......::::.:::::;:... 

....... .. -... :.....:::. 

CSA C22.2 No. 64-10 ...... 

........-.. .... 

. .. ..... 

.. . 

....... 

, 

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Revision Date Revised by 

Number 

• 

Reason for Change 

CTI Industries Corporation 

100 Series Vacuum Sealer Machines S.147 0 4 of4 

Frequency 

Input Power 

Power Cord (US/CAN) 

Plug Type (US / Canada Version) 

60Hz 

160W 

SPT2, 18AWG, 2C, 60degC, UL Polarized Plug, 0.69m 

exposed (not include the plug) 

NEMA / 2-pin 

Product Life Tests 

Each cycle is equivalent to evacuating an 8" x 11" (203.2mrn x 279.4mm) bag with a 50mm x 50mm 

Sponge block contained within the bag. 

One Year Limited Warranty Life 

Warranty Life Target 

Compliance Standards 

312 cycles / year x 1 year = 312 cycles 

312 cycles x 3.86 = 1,204 cycles warranty life 

The cETL version complies with the following standards: