Organization Name:

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

Requestor Representative:

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.

3.

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

4.

*

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/

7.

5. Requestor's relationship to the product:

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential information 

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

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1

Public Document

CLEAR2O UNIVERSAL WATER FILTER

Model(s): CUF1252

Unique Feature: Nano alumnia & glass fiber pleated filter media for <1 micron filtration

Material: PP plastic, pleated filter media 

Filter Capacity: 3 months

The CLEAR2O UNIVERSAL WATER FILTER fits 10X2.5 inch universal filter housings for 

whole house filtration. 

8421210000 Bernard, Keith Applica Water Products LLC n/a Purchaser YES Public Document
8. Is this product, or a comparable product, available from sources in the United States? (If you

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

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:

2016 Value:

2015 Value:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?

NONO 0 (new Q2 2018) 0 (new Q2 2018) 0 0

0 0

FINAL PRODUCT NEW n/a n/a
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).

Applica Water Products LLC is a very small, family-owned and operated, manufacturer of water 

filtration systems and sell under our CLEAR2O® brand. We source manufacture our own 

designs and sell water filtration systems as our only line of business, we are headquartered in 

Miramar, Florida.

Currently, 100% percent of our water filtration products are sourced from China. Of which, 90% 

of those imported water filtration products & filters are only available from China due to the 

location of our owned-tooling placed with 3rd party China manufacturers.

At present, our design & formulation is unique and thus comparable products are not available 

in the US or from other countries. Additionally, major infrastructure changes need to be 

implemented to facilitate reasonable priced products for the overall water filtration industry. 

Currently, the USA and other countries lack the equipment infrastructure to cost-effectively 

manufacture those parts needed to complete our line of products. 

Applica Water Products LLC will experience an economic hardship due to the additional ad 

valorem of 25 percent on all water filtration parts from China. Based on the annual volume of all 

combined water filtration parts and accessories, the total tariffs on the next rounds of 

containers will result in an immediate reduction of our net profits before taxes by a significant 

amount. As a result, this event will cause a reduction in jobs, sales jobs, access to financing 

options and / or higher financing costs.

As a small business in the water filtration industry, it will not be competitive to increase 

consumer prices to mitigate the cost of tariffs. Price increases will result in the loss of long-term 

and new customers. We are operating on a shoe-string budget. So, any internal cost cutting 

will severely impact our daily operations. The long-term impact of these untimely tariffs will 

result in net losses for our company, which ultimately reduces healthy competition in the water 

filtration industry.

Our water filtration parts and accessories are not a part of the Made in China 2025.

 In summary, we sincerely request that your office approves the exclusion of tariffs for Applica 

Water Products LLC due to this untimely economic hardship.

Sincerely,

Keith Bernard

President

Applica Water Products LLC

954-998-1909

Keith.bernard@applicawater.com

www.clear2o.com