Jg PRESTO* 

National Presto Industries, Inc. 

Eau Claire, WI 54703-3703 

October 3, 2018 

Via regulations.gov % 

wwwgopresto.com 

Tel. 715-839-2121 

Fax 715-839-2148 

715-839-2122 

715-839-2242 

Re: Request for Exclusion from National Presto Industries, Inc. for Pressure Relief 

Valves Classified as HTSUS 8481.10.0090 

National Presto Industries, Inc. ("NPI") is writing to express its deep concern with the Office 

of the United States Trade Representative's (USTR) proposal to use a 25% tariff increase to 

address China's unfair trade practices and its trade investment relationship with the United 

States. As explained in more detail below, NPI requests an exclusion from the tariff increase 

for its Pressure Relief Valve service part, which has a 10-digit HTSUS classification of 

8481.10.0090. The service part at issue is comprised of a relief valve and a nut. The internal 

Part Numbers are 79-368 (valve) and 25-159 (nut). The internal Service Number is 54778. 

Request for Exclusion of Pressure Relief Valves 

a) 10 Digit Subheading of the HTSUS Most Applicable to the Relief Valves 

HTSUS 8481.10.0090 

b) Identification of the Particular Physical Characteristics of the Relief Valves and 

How They Are Distinguishable From Other Products Coded 8481.10.00 

The 8-digit subheading HTSUS 8481.10.00 covers "pressure reducing valves for 

pipes, boiler shells, tanks, vats or the like." The pressure relief valves requested 

for exclusion by NPI are therefore distinguishable from other products within the 

covered 8-digit subheading 8481.10.00 in that they are used as service parts for 

small consumer household appliances, specifically 6-quart and 8-quart pressure 

cookers. Pipes, boiler shells, tanks and vats are not consumer household 

products. 

The relief valves at issue are comprised of a valve and nut, both of which are very 

small in size. The valves have a diameter of 1.38 inches; a height of 1.65 inches; 

and a weight of less than 0.1 pounds. The material composition of the valves 

contains aluminum, silicon and stainless steel. 

The nuts have a diameter of 0.69 inches; a height of 0.20 inches; and a weight of 

less than 0.1 pounds. The material composition of the nuts contains aluminum. 

c) Annual Quantity and Value of Relief Valves Purchased Last Three Years 

D 2015- Quantity: 29 Value: $108.75 

D 2016- Quantity: 39 Value: $146.25 

D 2017- Quantity: 68 Value: $255.00 

Trademark of National Presto Industries, Inc. 

880452D 
d) Relief Valves Only Available from China 

The pressure relief valves requested for exclusion are only available in China. 

These relief valves are critical for the safe operation of the cookers. The best way 

to assure that the parts meet specification is to have them manufactured on the 

same tooling that is used to manufacture the actual cookers. The demand for the 

impacted relief valves is such that it would not be feasible to tool or print those 

parts in the United States. 

e) Increasing the Tariff on Pressure Relief Valves Will Have No Impact on the 

Trade Deficit 

An increased tariff on NPI's service parts and small consumer appliances will 

have no impact on the trade deficit, but would increase the price of the part to the 

consumer. If the tariff goes through, NPI will continue to import the relief valves 

into the U.S. as long as there is a consumer demand to pay the higher price. If 

demand from consumers after the price increase drops to the point that offering 

the part is no longer feasible, the part will be discontinued. Given the dollars 

involved, discontinuance of this service part will have no impact on the trade 

deficit. 

f) Pressure Relief Valves Have No Strategic Importance to the Made in China 2025 

Program 

Stated simply, there is absolutely no correlation between the proposed tariffs on 

pressure relief valves for pressure cookers and the Made in China 2025 Program. 

Made in China 2025 is Beijing's plan to transform China into a hi-tech 

powerhouse that dominates advanced industries like robotics, advanced 

information technology, aviation, and new energy vehicles. 

Parts for pressure cookers have no strategic importance to that Made in China 

2025 Program. The Chinese are not interested in any intellectual property or 

technological innovations relating to these relief valves because the technology is 

dated. These parts have been features in pressure cookers since NPI introduced 

the first pressure cooker using a rotating lid and gasket during the World's Fair in 

1939. There are simply no innovations or technological advances to be made 

relating to these service parts. 

For the reasons stated above, NPI requests an exclusion from the tariff increase for its 

pressure relief valves, which have a ten-digit HTSUS classification of 8481.10.0090. I 

certify that the information provided herein is complete and correct to the best of my 

knowledge. 

Respectfully Submitted, 

Peter Furrer 

Associate Corporate Counsel