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AERUS LLC SECTION 301 EXCLUSION REQUEST for AP3000 (Model 9940040) 

PUBLIC DOCUMENT 

2.  Product Description 

Air Purifier Model 

Name  AP3000  

Model No.  9940040 

Dimensions 

12" high x 9" wide x 12" deep (30.5 cm x 22.9 cm x 30.5 cm)

Weight  10.2 lbs. 

Composition  ABS Plastic 

Filtration Methods  Proprietary Photocatalytic Ionization   

Safety Certifications  ETL (US and Canada) 

Other Certifications 

CE; FCC 

Other Notables    

3.  The 10 digit subheading of the HTSUS most applicable to the particular product requested for 

exclusion.

Response:  The Importation of the product is covered under HTSUS Code 8421.3980.15.  Section 8421 

covers “Centrifuges including centrifugal dryers, filtering or purifying machinery and apparatus for 

liquids or gases and parts thereof”.  3980 is a catch all “other” category.  Subsection 15 is “Other” in the 

“Other” category above and is where Consumer Residential Air Purifiers, parts and filters are covered.  

Imposing tariffs on products falling within this subsection 15 category appears to be an unintended 

consequence of the Administration’s stated objective of imposing tariffs on products imported from 

China which contain industrial significant technology.  Products under this subjection generally do not 

meet this criteria.  

10.  Value and Quantity Information 

Response:    The relative response includes BCI and can be found in our separate BCI submission.  

Disclosure of that information would endanger trade secrets or profitability and this information 

would not customarily be released to the public

11.  Please provide information in support of your request, taking account of the instructions 

provided in Section B of the Federal Register notice. 
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. 

Response:   The product falls under USHTS Code 8421.3980.15, was designed in the United States and 

utilizes the Company’s proprietary PCO and other technologies, which are key differentiators to all other 

air purification products on the market.  The product is manufactured to the Company’s exacting 

specifications to ensure efficacy, quality, performance and adherences to regulatory requirements to 

maintain product certifications.  Components listed in the bill of material for the product have been 

extensively tested to meet these specifications.   

Other portable residential air purification products which are available from sources outside of China 

don’t incorporate the technologies we develop and own.  Our products consistently out‐perform other 

portable residential air purification products in the elimination of mold and odor causing bacterial and 

pathogens.  There are simply no comparable products available from sources in the United States 

and/or other countries and because of the technologies involved and complexities of product 

component part supply it would be difficult to transition manufacturing outside of China. 

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

harm to the requestor or other U.S. Interests. 

Response:   The additional duties imposed under the tariff will cause severe economic harm to both (i) 

the Company and its employees and (ii) the thousands of independent distributors that market and sell 

our product.  The Company maintains an approximate 400,000 square foot distribution and 

manufacturing facility in Bristol, VA and employs approximately 200 people.  Our products are 

warehoused and distributed at this facility and are marketed and sold through the Company’s 

independent distributor network. 

Vollara’s business model is based on the concept of 360◦ of Wellness which is comprised of (i) 

maintaining a healthy body through our proprietary line of vitamins and nutritional supplements 

produced in the United States and (ii) maintaining a healthy home by using the product.  Our 

independent distributors utilize the lower cost vitamins and nutritional supplements for customer 

acquisition and introduction to the 360◦ of Wellness concept but sell the product at a premium price 

point to generate the vast majority of the profits for their independent business.   This system has been 

proven out over the years and results in sales necessary for our distributors to sustain their independent  

businesses.   Because of limited consumer price elasticity, the imposition of the tariff will result in lost 

sales and business failures for our distributors.  This will impact our profits and in turn our ability to 

maintain our facilities and employees.  

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

Chinese industrial programs.
Response:  The product is not important or relevant to Made in China 2025 or other Chinese industrial 

programs. 

Requestors may submit information on the ability of U.S. Customs and Border Protection to administer 

the exclusion. 

Response:  The product is produced by a single manufacturer and shipped directly to the Company in 

cargo containers resulting in simple administration by U.S. Customs and Border Protection.