September 19, 2018

Office of the United States Trade Representative

Re: Docket Number USTR-2018-0025

Tanita Corporation of America hereby requests exclusion of products from the Determination 

of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation. The subject products are consumer personal 

weighing scales designed by Tanita Corporation of Tokyo, Japan, and manufactured at a Tanita 

Factory in Dongguan City, China. Tanita’s principle business is weighing devices.

The consumer personal weighing scale model numbers are:

BC-533

BC-549

BC-549Plus

BC-554

BC-577F

BC-585F

BC-585P

BC-730F

BF-679F

BF-679W

BF-680W

BF-684W

RD-901plus

RD-953

UM-081

All of these models are designed by Tanita for personal use, in a consumer setting. They will 

provide the user their body weight along with body fat and other measurements using a 

process called bioelectric impedance. These specific scale model numbers are manufactured in 

China, they are not available from other sources in the United States, or third countries.

These scales have been classified with a Harmonized Tariff Schedule code of 9018.19.5500, 

which is now subject to the 25% tariff. Examination of the 2018 Schedule shows the definition
of products that fall within the 9018 category to be: Instruments and appliances used in 

medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other 

electro-medical apparatus and sight-testing instruments; parts and accessories thereof. We 

believe that the products found within this category are for intended use in a clinical or 

professional setting, not the home. We are requesting exclusion from the addional tariff on our 

consumer home use scales for this reason.

Alternatively, we suggest the reassignment of the Harmonized Tariff Schedule code for these 

products to 8423.10.00. The 2018 Schedule shows the definition of products that fall within 

this category to be: Personal weighing machines, including baby scales; household scales. We 

believe this better describes the intended use of the subject Tanita scales.

The imposition of the additional duties on these products will cause severe economic harm to 

Tanita Corporation of America. These consumer personal weighing scales have low retail price 

points, in a highly competitive marketplace. Our margins will suffer staggering consequences, 

or will we be forced to raise our prices, and no longer be competitive. And we do not believe 

any of our competitors have been imposed with these new tariffs.

Finally, we do not consider these consumer scales to be of strategic importance to China or 

related to Made in China 2025. These would not be considered high-performance medical 

devises (such as video equipment and medical robots) that China has previously identified.

Supporting documenting:

Attachment 1. Tanita catalog showing these models as consumer personal weighing scales.

Attachment 2. Tanita warranty card showing that we only intend these scales for personal use.

Attachment 3. Tanita.com web page showing these listed within the consumer section.

Attachment 4. Three years history for products subject to addional duties, BCI version.

Attachment 5. Three years history for products subject to addional duties, public version.

Thank you for your attention to this matter.

Keith Erickson

National Sales Manager

Tanita Corporation of America, Inc.