YINLUN TDI,. 

THERMAL DYNAMICS 

4850 E Airport Dr • Ontario, CA 91761 

Tel: +1(909) 390-3944 • Fax: +1(909) 390-3950 

www.yinluntdi.com 

SECTION 301 (CHINA) 

DOCKET No. USTR-2018-0026 

PUBLIC SUBMISSION 

August 29, 2018 

VIA ELECTRONIC SUBMISSION (rrrp://www.REGULATIONS.Gov) 

Ambassador Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

600 Seventeenth Street, NW 

Washington, DC 20508 

Attention: Arthur Tsao, Assistant General Counsel, USTR 

Justin Hoffmann, Director of Industrial Goods, USTR 

Office of the United States Trade Representative 

Re: Comments on Proposed Modification of Action pursuant to Section 301 

Determination regarding China's Acts, Policies, and Practices related to 

Technology Transfer, Intellectual Property, and Innovation (Docket Number 

USTR-2018-0026) 

Dear Ambassador Lighthizer: 

We respectfully submit the following comments in support of our request to exclude a 

heat exchange unit made of Aluminum classified under subheading 8419.50.1000 of the 

Harmonized Tariff Schedule of the United States ("HTSUS") from the list of products subject to 

a 25 percent ad valorem tariff pursuant to the determination of the Office of the U.S. Trade 

Representative (USTR") in connection with above-referenced proceeding. 

These comments are timely submitted. { See Procedures To Consider Requests for 

Exclusion of Particular Products From the Determination of Action Pursuant to Section 301: 

China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and 

Innovation, 83 Fed. Reg. 32,181 (July 11, 2018). } 

The product subject to this exclusion request is a heat exchange unit made of aluminum, 

known as a "aluminum nested plate heat exchange'. This product is primarily used to cool 

engine or transmission fluid for automotive passenger cars and recreational vehicles. It can also 

be used to heat a hybrid vehicle lithium-ion battery. It is composed of uniquely designed plates 

used to exchange thermal energy between two liquid streams (oil and coolant). 
g

YIN LUN TDILLC 

THERMAL DYNAMICS 

4850 E Airport Dr • Ontario, CA 91761 

Tel: +1(909) 390-3944 • Fax: +1(909) 390-3950 

www.yiniuntdi.com 

The dimensions of these heat exchange units vary depending on the applications for 

which they are designed and engineered and in which they will be installed. Their heights range 

from 1 y2 to 5 inches; their lengths from 3 to 12 inches; and their widths range from 3 to 12 

inches. 

U.S. Customs and Border Protection ("CBP") will be able administer the requested 

exclusion by noting the description on the commercial invoice accompanying the entry by 

Yinlun TDI, LLC. It reads: "Al NPHx Oil Cooler." The acronym "Al NPHx" stands for 

"aluminum nested plate heat exchange', and it is unique in Yinlun's product descriptions for 

this product. 

Yinlun's annual quantity and value of imports of this product from China for 2015 — 

2017 have been: 

Calendar Year Quantity Import Value 

2015 130,241 pcs $1,112,091 

2016 110,891 pcs $950,873 

2017 157,702 pcs $1,455,639 

Each part — such as the aluminum nested plate heat exchanger which is the subject of this 

exclusion request — is unique to the vehicle and application in which it is used, and the part was 

developed to meet specific vehicle performance, durability, and installation requirements. The 

design of the product belongs to Yinlun TDI, LLC. 

It normally takes two years of research and development as well as extensive testing to 

design and validate each part. The cost of the development was a major investment not only for 

Yinlun TDI, LLC but also for our customers. The product as designed cannot be produced in the 

United States or elsewhere, and the imposition of the 25-percent tariff will have a major financial 

impact on our company and ultimately on our employees. It will also have a financial impact on 

our customers, driving up the cost of the vehicles they produce. 

Yinlun TDI, LLC is a leading global manufacturer of Thermal Management and Exhaust 

Emissions Treatment product solutions. We provide world class customized products and 

engineering services to our customers in the passenger car, commercial vehicle, and industrial 

markets. Our company has a long history of more than 100 years and employ more than 100 

people with facilities in California, Michigan, North Carolina, and Illinois. Yinlun TDI, LLC is 

growing its manufacturing and distribution facilities in the United States. This expansion will 

create new skilled and unskilled jobs. However, the impact of the increased tariffs will have a 

significant adverse impact on our ability to execute these expansion plans and will affect our 

current employment levels. 

This product is not strategically important to the "Made in China 2025" program or any 

other export promotion programs. 
&YINLUN TDILLC 

THERMAL DYNAMICS 

4850 E Airport Dr • Ontario, CA 91761 

Tel: +1(909) 390-3944 • Fax: +1(909) 390-3950 

www.yinluntdi.com 

We had been very optimistic and excited about our future plans to expand our operations 

in the United States, but as the result of the 25-percent tariff, we are very worried about our longterm financial viability. For these reasons, we respectfully request that our "Aluminum NPHx", 

classified as a heat exchange unit under HTSUS subheading 8419.50.5000 be excluded from the 

list of products subject to the 25-percent tariff. 

We are available to provide additional information and respond to any questions that you 

may have. 

Sincerely, 

Sheila Stoker 

Executive Vice President 

(909)740-6448 Office 

(909)208-5286 Cell Phone 

sstoker@yinluntdi.com