JMW Sales, Inc.

Public Filing for Section 301 Exclusion

▪ Any request for exclusion must include the following information:

o Identification of the particular product in terms of the physical characteristics (e.g., 

dimensions, material composition, or other characteristics) that distinguish it from other 

products within the covered 8-digit subheading. USTR will not consider requests that 

identify the product at issue in terms of the identity of the producer, importer, ultimate 

consumer, actual use or chief use, or trademarks or tradenames. USTR will not consider 

requests that identify the product using criteria that cannot be made available to the 

public.

• Our company product is directly affected by the imposition of these new tariffs. The 

product is our Starter Kit rock tumbler (1lb. plastic barrel) sold under the brands of 

National Geographic and Discover with Dr. Cool.

o The 10-digit subheading for the HTSUS most applicable to the particular product 

requested for exclusion.

• 8464.20.0120

o Requestors also may submit information on the ability of U.S. Customs and Border 

Protection to administer the exclusion.

• Exclusion would be easy to administer for our company. The rock tumbler is

outlined on our commercial invoices and packing slips with the HTS code 

8464.20.0120, so this is easy to process for U.S. Customs. 

o Requestors must provide the annual quantity and value of the Chinese-origin product 

that the requestor purchased in each of the last three years. For trade association 

requestors, please provide such information based on your members’ data. If precise 

annual quantity and value information is not available, please provide an estimate and 

explain the basis for the estimation.

• Annual quantity and value 

[2017 Value: REDACTED 2017 Quantity: REDACTED]

[2016 Value: REDACTED 2016 Quantity: REDACTED]

[2015 Value: REDACTED 2015 Quantity: REDACTED]

▪ With regard to the rationale for the requested exclusion, each request for exclusion should 

address the following factors:
o Whether the particular product is available only from China. In addressing this factor, 

requestors should address specifically whether the particular product and/or a 

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

countries.

• This product is only available from China. While our product line falls under the 

heading for larger capacity industrial machines, these are all small rock tumblers 

that are marketed and meant for the hobbyist. They serve no industrial purpose, 

as the maximum capacity for polishing stones is 1lb. These products have taken us 

years of research, development, and implementation to accomplish. There is not a 

readily available supply chain in the United State to support our product design 

and quality requirements. Comparable products are also not available in the 

United States or third countries.

o Whether the imposition of additional duties on the particular product would cause 

severe economic harm to the requestor or other U.S. interests.

• The cost of the additional tariff would cause severe economic harm to our 

company and threaten planned investments and research and development 

spending. The manufacturing, design, marketing and distribution of these rock 

tumblers engage U.S. workers from our office in Oregon to our warehouse in 

California. Maintaining and growing these well-paying manufacturing and support 

jobs is critical to the communities where they work and the U. S. economy. 

Further, our products offer hands-on learning, and educational content is included 

in each kit teaching about Rocks and science. By imposing a 25% tariff on our 

tumblers, the sales price would have to be increased making these tumblers 

unaffordable for many American families, and depriving opportunities to children 

for such STEM learning. As this administration supports an agenda that “better 

prepares students to compete in a global economy” (whitehouse.gov) the

importance of teaching kids science is a critical part of this objective, and should 

not be overlooked.

o Whether the particular product is strategically important or related to “Made in China 

2025” or other Chinese industrial programs.

• This product is not related or relevant to “Made in China 2025” or any other 

Chinese industrial programs that we are aware of. As niche consumer goods, a 25% 

tariff will have no impact on China; it would only hurt an American company and 

our customers.