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 product of concern:

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

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.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

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

VERSION 1

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).

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

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

October 6, 2018 

VIA REGULATIONS.GOV PUBLIC DOCUMENT

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025 

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Re: Request for Exclusion of Automobile Heads Up Displays under HTSUS 9031.80.8085 from the 

Determination of Action Pursuant to Section 301 

Dear Ambassador Lighthizer:

Scosche Industries, Inc. (“Scosche”) respectfully submits this request for exclusion of Automobile 

Heads Up Displays from the proposed determination of action pursuant to Section 301 of the Trade Act of 

1974.1

 

Scosche was founded in 1980 as a family-owned and operated enterprise, and is based in Oxnard, 

California. Scosche is an internationally recognized, award-winning innovator of consumer technology and car 

audio products. We maintain offices in three U.S. States plus Shenzhen, China and have over 140 employees 

located in four countries. 

Scosche provides car audio installation hardware and portable electronics accessories. It offers dash kits, 

harnesses, antennas and adapters, tools, amplifiers, speakers, subwoofers, speaker enclosures, Bluetooth 

products, interfaces, distribution blocks, power and audio cables, mobile accessories, and installation 

 

1

 19 U.S.C. § 2411. 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

accessories. Scosche’s product portfolio encompasses thousands of skus spanning the consumer technology and 

car audio arena. Scosche products are sold in over 50 countries by a wide array of the most recognized names 

in retail.

This exclusion request addresses Automobile Heads Up Displays classified under HTSUS subheading 

9031.80.8085, which are currently subject to the 25% additional Section 301 tariff. Please note that a separate 

Section 301 Investigation Form to Request Exclusion of Product has been submitted for each unique part 

number for which we are requesting an exclusion. 

In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2

 Scosche provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China, i.e. whether the particular product and/or a 

comparable product is available from sources in the United States and/or in third countries

The Automobile Heads Up Displays that are the subject of this exclusion request are not 

available outside of China. Currently, our company sources the Automobile Heads Up Displays from 

extensively vetted suppliers in China. There is no readily available alternative U.S. or third country source 

outside of China from whom we can source these products. 

Further, the Automobile Heads Up Displays cannot be sourced from other countries as all of our tooling, 

certifications and logistics for this product are located in China. To engage new suppliers would entail an 

onerous process of: (1) identifying vertically integrated suppliers, including sub-suppliers, in other countries; 

 

2 Procedures To Consider Requests for Exclusion of Particular Products From the Determination of Action 

Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual 

Property, and Innovation, 83 Fed. Reg. 32,181 (USTR July 11, 2018). 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

(2) once identified, making sure such suppliers maintain facilities that adhere to labor laws consistent with US 

standards; and (3) retooling the product in accordance with the specifications of our customers. Our current 

suppliers have passed vital social responsibility, safety and security audits required by U.S. retailers. Scosche is 

contractually required to use audited, certified and approved suppliers. Our suppliers have already been 

qualified and to change suppliers would require us to repeat this process and request a contractual amendments 

from our customers. 

With new suppliers, we would have to recertify all suppliers, placing our whole infrastructure in 

jeopardy. We estimate that the recertification process would take a minimum of two years, in addition to 

another year of social responsibility, security and safety audit standards. We expect that lead times for this 

product will more than double due to supply chain constraints and lack of vertical integration. 

 Given its reliance on its current supply chain in China, Scosche has significant capital investment in 

tooling in China. Relocations of our tooling outside of China would cause extended interruptions to Scosche’s 

production. To mitigate the impact of such interruptions, Scosche would need to make significant capital 

expenditures to duplicate its tooling in multiple locations, which would cause extreme financial hardship to our 

company and, as detailed below, threaten our continued operations and employment levels in the United States. 

Our practice of importing Automobile Heads Up Displays is consistent with that of our leading 

competitors, which also import product from China. 

2. Whether the imposition of additional duties on the particular product would cause severe 

economic harm to the requester or other US interests

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

The Automobile Heads Up Displays at issue improve the safety of operating an automobile by 

displaying relevant vehicle data on the windshield. These products are sold in mass merchant retail with a slim 

profit margin, providing low pricing to the end consumer. Although the Automobile Heads Up Displays do not 

support any down-stream manufacturing in the U.S., they are a key innovation to the American consumer 

electronics experience and U.S. consumers rely upon these products every day. 

The imposition of a 25% duty increase would have a negative impact on our U.S. profits and 

employment. These products are not an absolute necessity but they do provide consumers added convenience 

and an enhanced consumer experience. If the pricing increases, consumers may simply decide to no longer use 

our product. As a major supplier of Walmart, BestBuy, and Target etc., the ramifications of losing this line of 

business would be devastating to Scosche and its employees in the United States. 

The 25% duty increase effectively negates our low profit margin, which would, by necessity, be passed 

directly to our retail customers. These customers have confirmed that these increased costs would ultimately be 

passed on to end consumers. Many of our customers have communicated directly with legislators on this 

extremely important issue. These tariffs will directly affect our bottom line, profit sharing and employment 

budget. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or 

other Chinese industrial programs

The Automobile Heads Up Displays are not strategically important, nor related to any other Chinese 

industrial programs, including “Made in China 2025.” Specifically, the Automobile Heads Up Displays are not 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

a low technology product but they are imported to facilitate the implementation of high technology replacement 

stereo head units in the United States. The product is produced by a non-affiliated third party supplier. 

There are no U.S. patents or trademarks covering this product, and no intellectual property rights have 

been transferred to Chinese producers. These Automobile Heads Up Displays are produced in China to our 

specifications and for our exclusive use. We have transferred no intellectual property rights to our suppliers in 

China nor are we required or expected to do so. 

We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

 Respectfully submitted,

 

 ___________________ 

 Christopher Norris 

 Global Logistics Coordinator

 Scosche Industries 

 (800) 363-4490, 122 

 chrisn@scosche.com 

~ ~LCJ~C? II=* 

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