Section 301 Investigation: China's Acts, Policies, and Practices Related toTechnology 

Transfer,Intellectual Property, and Innovation - Form to Request Exclusion of Product

When submitting a product exclusion request using this form, enter the specified 

informationinthefollowingfieldsandexplainthebasisandrationaleforyourstatements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge.

1. Indicatewhetherthe comment containsbusiness confidentialinformation(BCI),is apublic

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

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

3. 10-digitHTSUSitemnumber*forproductyouwishtoaddressinthisproductexclusionrequest:

*Usenumerical characters onlywith no special characters (example: 1023456789).Forhelpinfinding

the HTSUS itemnumber associated with your product, see https://hts.usitc.gov/

8525.60.1030

4. Requestor Information

Requestor Name (Last, First):

Organization Name:

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

Requestor Representative:

5. Requestor's relationship to theproduct:

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

7. Pleaseindicatewhetheranyadditionalattachment containsbusiness confidential

information (BCI), is a public document, oris a public version of a BCI document.

No

Public Version

The requested exclusion is for dual band VHF and GMRS two-way radios designed for marine 

applications. The specific Cobra-brand model at issue is MR HH450 DUAL, which is a 6-watt, hand-held 

marine. The unit is composed of plastic, steel, aluminum and electronic components. Detailed product 

specifications, including dimensions, are attached.

No

Linda J. Engell, V.P. Supply Chain & Operations

Cedar Electronics Corporation

Importer

Barnes, Richardson & Colburn – Lawrence M. Friedman
8. Is thisproduct, or a comparableproduct, available fromsources intheUnitedStates?:

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

10. Pleaseprovide thevalue andquantity (withunits) oftheChinese-originproductof concern 

thatyoupurchasedforeachcalendaryearspecified.Limitthis figuretotheproducts 

purchased by your firm (or by members of your trade association) alone. Please provide 

estimates if precise figures are unavailable.

2015 2016 2017 2018 (Est.)

Units [Table Redacted]

Dollars

11. Please provide information in support yourrequest, taking account ofthe instructions 

provided in Section Bofthe Federal Register notice (note:text entered below can extend 

beyond the apparent size of this box).

No

Yes
The Cobra radio brand dates back to 1963 when Dynascan, the predecessor company, brought its first CB 

radios to the marketplace. After diversifying into other products including radar detectors, police 

scanners, cordless phones and answering machines, Cobra entered the marine radio and navigation market 

in 2003. Cobra is now a brand of Cedar Electronics, which also produces a full line of dash cameras and 

power accessories. Cedar has 141 employees in the United States in its Chicago, Illinois and West 

Chester, Ohio locations. These U. S.-based employees include manufacturing support and engineering for 

the design and development of new products including marine radios and CB radios integrated via 

Bluetooth with smartphones. 

Severe Economic Harm 

Because there are no manufacturers of marine radios in the U.S., the current 25% duty creates a 

significant competitive disadvantage for Cobra. Cobra estimates an annual cost of [

]. Our contribution margin is [ ]. Absorbing the 

additional cost would [ ]. Ninety-five percent of 

boats in the U.S. are small, towable vessels under 26 feet in length. Seventy-two percent of boaters in the 

U.S. have an annual household income of less than one hundred thousand dollars ($100,000). Based on 

these figures, the majority of customers for Cobra's marine radios are working class individuals 

purchasing a necessary safety device. As a result of these duties, these individuals will see the cost of 

Cobra safety equipment increase. Faced with that reality, Cobra's customers will probably stop buying the 

"American" brands available to them to instead buy the cheaper Japanese product. 

Available Source Countries 

Marine band radios are manufactured in China, Japan and Vietnam. They are manufactured using a 

mature technology with no alternative use, as such, it is unlikely that a company will invest in establishing 

a manufacturing facility to create these products. Cobra is the market leader with a [ ] market share in 

North America for vessels at or below 30 feet in length. Cobra's main competitors are: 

Company Headquarters Manufacturing Est Market Share

Uniden Japan Vietnam 21%

Icom Japan Japan 11%

Raymarine United Kingdom China 4% 

Simrad Norway China 2%

Standard Horizon USA China 23%

Garmin USA China 5%

All U.S.-based marine radio companies are manufacturing in China. Therefore, all U.S. manufacturers 

will be negatively impacted by this duty with a correlating benefit to the Japanese companies. 

Made in China 2025 

While Cobra continues to innovate, marine band radios are a mature technology that is critical for the 

safety and communications of boaters nationwide. There is no indication that short-range, mobile radio 

transceivers have or will benefit from China's policies relating to intellectual property rights and 

technology transfer. Marine band radios are not part of the Made in China 2025 initiative. These products 

have no application to cloud computing, the Internet of Things, autonomous vehicles, agricultural 

equipment, semiconductors, and battery technology. Thus, removing marine band radios from the list of 

items subject to the 301 duties does not further the interests and policies these duties are intended to 

combat. 

Ease of CBP Administration

These products are labeled and invoiced as VHF marine radios. Thus, they are easily distinguishable 

among products in this 8-digit classification. 
All-Terrain-RadioTM

Use on boats, ATVs, snowmobiles,

roadtrips and many other uses.

Rewind-Say-Again®

Replay missed VHF calls.

Privacy combinations

1815 GMRS privacy combinations.

FLOATING

Never lose your radio. Floating design 

and orange core makes retrieving the 

radio easy if dropped overboard.

Weather Alert with S.A.M.E.

Weather and emergency alerts only if 

threat is nearby.

Ultra-Compact Design

Ergonomic, rugged and compact 

design is easy to hold and intuitive 

to operate.
Cobra®, CobraMarine®, Nothing Comes Close to a Cobra®, MicroBlue® ,Rewind-Say-Again®, and the snake design are registered trademarks of 

Cobra Electronics Corporation, USA. Cobra Electronics CorporationTM is a trademark of Cobra Electronics Corporation, USA.

©2014 Cobra Electronics Corporation, 6500 West Cortland Street, Chicago, IL 60707, USA

MRHH450 DUAL SP 2/14 Nothing Comes Close to a Cobra®

Features Benefits

Included Accessories

All-Terrain RadioTM Dual Band Receive and Transmit. One BAND button allows you to switch from the GMRS to 

VHF bands. You can talk to GMRS users on the dock or ashore and easily switch to the VHF 

Band for routine or emergency vessel to vessel or vessel to shore communications.

Rewind-Say-Again® Replay missed VHF calls. Automatically records the last 20 seconds of incoming audio.

FLOATING Never lose your radio. Floating design and orange core makes retrieving the radio easy if 

dropped overboard.

Noise-Canceling Microphone Blocks background noise for clearer conversations.

6 Watt VHF and High Power GMRS Select between Low, Medium and High power for short and long range communication.

U.S.A., Canada & International Channels Allows operation on any of the three (3) different channel maps established for these areas.

All NOAA Weather Channels Instant access to national All Hazards and weather information, 24 hours a day.

Weather Alert with S.A.M.E. Alerts with audible tone and visual alarm only if threatening weather is nearby. 

S.A.M.E. (Specific Area Message Encoding) allows setting your local area and filtering out 

warnings from further away.

BURP Vibrates water out of the speaker grill and improves speaker performance.

Patented VibrAlert® Enhanced vibrating feedback to notify you of incoming transmissions.

VOX The user’s voice is detected and the radio transmits without the need to press any buttons, 

freeing hands for other tasks. Five VOX sensitivity levels allow the user to select at which 

point the radio will detect their voice.

Advanced GMRS Scan Allows the user to scan either channels, CTCSS privacy codes within a channel, DCS codes 

within a channel, or up to 10 memory locations to locate conversations in progress.

Rated Submersible Meets JIS7 (IPX7) standards; submerible for 30 minutes in one meter 

deep water.

External Speaker/ Microphone Jack Connect Cobra speaker mic accessories for hip or body worn operation.

Instant Channel 16 Instant access to channel 16 for emergency marine situations.

Unlimited Memory Channels Allows programming of unlimited channels for easy retrieval or scanning.

Tri-Watch Monitors three (3) channels at once - channel 16 and two (2) user selected channels.

Scan Scan all channels to find conversations in progress.

Advanced Memory Scan Scan channels programmed in memory to find conversations in progress. Cross-band 

scanning allows scanning for conversations on both saved and GMRS channels.

Signal Strength Meter Shows the strength of the receiving and transmitting signal.

Button/Key Lock Locks function buttons/keys to eliminate accidental change of settings.

Battery With Charge Contacts Allows charging of batteries in unit.

Illuminated Function Keys Allows high visibility of function keys.

Selectable Key Tone Beep Key tone press beeps can be turned off to silent operation. 

Large, Illuminated LCD Display Allows high visibility of display. 

3 Year Warranty (on radio) For products sold in the U.S.A.

CM 110-026 1000mAh LiON Polymer Rechargeable Battery (black color).

CM 110-030 Locking Desktop Charger.

CM 120-005 AC Adapter with North America Plug.

CM 130-005 12V DC Accessory Plug.

CM 300-003 Replacement Dual Band Antenna (VHF/GMRS).

CM 240-003 Spring-Loaded Belt Clip.

Optional Accessories

CM 110-024 Alkaline battery tray. Use with AA Alkaline Batteries.

CM 330-001 Lapel speaker/mic.

CM 110-026 Replacement or back-up 1000 mAh LiON Polymer Rechargeable Battery (black color). Floats if Dropped

Replay Missed VHF Calls

Unit Specifications

General

Dual Band Receive & Transmit

Number of Channels All: U.S.A., Canadian,

International, 10 NOAA Weather

Channels, GMRS- 15 Channels

Channel Spacing 25 kHZ

Modulation 5 kHz Max.

Input Voltage 7.4 VDC

Battery Life: 5% TX, 5% RX, 90% Standby

8 Hours @ 6 Watts

16 Hours @ 1 Watt

Battery Requirements Cobra Battery Pack

CM 110-026

Current Drain:

 Stand-by 45 mA

 Receive 200 mA

 Transmit 1.8 A @ High Power

700 mA @ Low Power

Temperature Range -20oC to 50oC

Unit Dimensions 11.65” H x 2.70” W x 2.17” D

(including antenna)

(296 mm x 68.5 mm x 55.2 mm)

Unit Weight (Lbs) 0 lb., 9.61 oz. (272.3 g.) 

(without accessories)

Receiver

Frequency Range VHF- 156.050 to 163.275 MHz

GMRS- 462.550 to 467.7125 MHz

Receiver Type Double Conversion 

Super-Heterodyne

Sensitivity: 12 dB Sinad -121 dBm

Adjacent Channel Selectivity -60

Intermodulation and Rejection -70

Spurious & Image Rejection -60

AF Output 250 mW @ 8 Ohms

Transmitter

Frequency Range VHF- 156.025 to 157.425 MHz

GMRS- 462.550 to 467.7125 MHz

RF Output Power 1, 3 or 6 Watts (VHF)

1, 2 or 3 Watts (GMRS)

Spurious Emissions -60 dB @ High Power

-55 dB @ Low Power

Frequency Stability +/-5 ppm

FM Hum & Noise 40 dB

Packaging Specifications

Individual Box 11.22” H x 9.45” W x 3.07” D

Dimensions (285 mm x 240 mm x 78 mm)

Individual Box Weight 1.7 lbs. (770 g.)

Master Pack Qty. 2

Master Pack Dimensions 11.02” H x 7.09” W x 8.86” D

(280 mm x 180 mm x 225 mm)

Master Pack Weight 4.10 lbs. (1860 g.)

SKU # MR HH450 DUAL

UPC # 0 28377 20164 6

Master Pack Barcode 5 0028377 20164 1

Specifications subject to change without notice.