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. 

I. Indicate whether the comment contains business confidential information (BCI), is a public 

document, or is a public version of a B CI document. 

Public Version of BCI 

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

Swivel Assembly. Please see part specification below. 

Inlet Valve: 1/2" NPT Threaded 

Outlet Valve 1/2" NPT Threaded 

Outlet Valve Elbow Height: 1.520 in 

Material: Carbon Steel 

3. I0-digit HTSUS item nuinber* 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/ 

8479909496 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Anway, Karl 

Reelcraft Industries 

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

Requestor Representative: 

5. Requestor's relationship to the product: Importer 

6. Does this submission in regulations.govinclude additional attachments? 

NO 

7. Please indicate whether any additional attachment contains business confidential 

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

Public Version of BCI 

VERSION 1 CONTINUED BELOW 1 
8. Is this product, or a comparable product, available from sources in the United States?: 

NO 

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

NO 

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. 

2017 Value: 2017 Quantity: 

2016 Value: 2016 Quantity: 

2015 Value: 2015 Quantity: 

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). 

1. This product is only available from the existing source in China, an American-owned company operating in 

China which sells to Asian markets while also trading parts with its sister cornpany in the United States. The 

design for this product is specific to the individual Bill of Materials of reels manufactured in America. It is not 

mass produced or readily available, and is in fact only traded through intra-company sales. 

This product also requires tooling which represents a substantial cost, and would require several months 

worth of design and manufacturing before a domestic source could be obtained. 

2. The imposition of additional duties on this product would cause severe economic harm to Reeicraft 

Industries. An increase in duties essentially amounts to an increase in costs, which will impact our employees, 

customers, and community. This reduces our ability to increase wages for American workers, as well as 

provide the outstanding benefits that allow them to prosper and grow within the local community, boosting 

the local economy, and help to keep America the prosperous nation it is today. 

The increase in costs risks the possibility of a reduction in workers, a reduction in workers pay and benefits, 

or an increase in prices which would prompt customers to favor foreign competitors and become a loss for the 

American economy at large. 

3. This product is not related to "Made in China 2025" or other Chinese industrial programs to the best of our 

knowledge. This is a low-technology industrial component which represents no strategically important 

econornic factor for our current trade relations. 

VERSION 1 END 
.....--- 1 1 N 

. 

_ ( 2 . 2 2 0 ) 

''s• ) IV 

Mil 0 

POI (3.350) 

III 

IP 

ii!bmil 

0 li i 

. • . . 

PHOJECEICR: @ -F:3. likl-ss °THERESE °TEE: DIKENSIONS ARE AFTER PLATING TOLERENCES M(SS NOTED): 

THE PRODUCT SHALL NOT 

CONTAIN NEXAVALEKT 

ENENSIONS ARE IX INCHES. 

MOVE BURRS. OXIDE 

LENGTH ANGLE 

- - 

CHROMIUM IN CONCENTRATIONS 

ABOVE 0.11 WI ON EACH 

SOMOGENOVS1ATERIAL 

SCALE. 

HEM SHARP EOM. 

CORNERS NOT TO EXCEED .015 

KAM SURFACES ARE VT25 Mg 

X.8 t .1 X.X" t .5" 

X.XX t •. 06 X.XX' t .05' 

X.XXX t .005 COAC.1.1,R .010 

. . . . 

MATERIAL: 

CARBON STEEL 

-DESCRIPTION: RE NO. XXIII 

FINISH: SW I VEL ASSEMBLY 

REDRAWN TO CREO 6/12/18 NO FINISH El 17756 Ruoff: 

1.020 LB. 

Oa HER: 31 FILENAME SIEEI: 

REV. DESCRIPTION ECN DATE AMOR: 

AJS 

SCALE: 

1: 1 

SHEET SIZE: 

B 

602096 I OF I