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. 

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

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

 Public Document 

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

 This is a magnet is made from ferromagnetic material, which includes Ferrite. It is 545 x 

18 mm, it weighs 0.005kg. 

3. 10-digit HTSUS item number* 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/ 

 8505907501 

4. Requestor Information: 

 Requestor Name (Last, First): Cournoyer, Paul

 Organization Name: Inteva Products

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

 Requestor Representative: Leslie Glick, Butzel Long 

5. Requestor's relationship to the product: 

 Purchaser 

6. Does this submission in regulations.gov include 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. 

 No
 2 

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? 

Yes 

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: 353,455 2017 $/Unit: 0.103 2017 Quantity: 3,694,700 

2016 Value: 120,069 2016 $/Unit: 0.0947 2016 Quantity: 577,481 

2015 Value: N/A 2015 $/Unit: N/A 2015 Quantity: N/A 

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). 

The product can be supplied from either Arelec SAS in France, or JPMF in China. Arelec 

SAS currently supplies Inteva’s plants in France and China, but not in the United States. Inteva 

did not start business with Arelec SAS in the United States, because Arelec SAS began to suffer 

financial instability in 2016. 

 The part was initially produced in France and switched to Chinese supplier due to French 

supplier having production issues and financial instability, current supplier is also dramatically 

cheaper. Inteva’s current alternate supplier is also located in China. In addition to these issues, if 

Inteva were to currently switch to an alternate supplier, not including the price of packaging or 

freight, there would be an increase for the price per part. Inteva would also have to ensure that 

the part is ready for production at the supplier, it would have to undergo testing and validation to 

ensure comparable performance, and all of these changes would have to be approved by the 

customer. This process usually takes a minimum of nine months. 

 Inteva currently pays 0.10 Euros. 

 This product is not strategically important for China’s 2025 program. 
mrrevHRyA

CERTIFICATION

I hereby certify that the information provided is complete and correct to the best of my knowledge.

( , jessica A. Davis

Purchasing Coordinator, Inteva Products