Public Document

The product is a multiple layer ceramic capacitor, which is a fixed-value capacitor in which ceramic material acts as 

the dielectric. Multilayer capacitors consist of a monolithic ceramic block with comb-like sintered electrodes. 

These electrodes come to the surface at the face ends of the ceramic block where an electrical contact is made by 

burnt-in metallic layers. A diagram of a multiple layer ceramic capacitor is attached at Exhibit 1. The LWH 

dimensions of this product are 0.18" x 0.10" x 0.08" and the weight of the product is less than 1 gram. Multilayer 

ceramic capacitors are packaged in tape and reel or in bulk, as shown in Exhibit 2. The HTSUS code 8532.24.0020, 

product name (multi-layered ceramic capacitor), and Country of Origin China are printed on the commercial 

invoice as shown in the example included at Exhibit 3.

8532240020

Bell, Christian

Knowles Corporation

Kay Georgi, Arent Fox LLP

Importer

YES

Public Document

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 BCI document. 

I I 

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

3. I 0-digit HTS US 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/ 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

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

Requestor Representative: 

5. Requestor's relationship to the product: 

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

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. 

VERSION 1 CONTINUED BELOW 1 
NO

NO

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*This product was not imported in 2016 and 2017, but we will continue to import this product to 

fulfill customer orders in the foreseeable future due to expected future demand. 

See attached for arguments in support of this exclusion request at Exhibit 4.

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

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

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. 

2017Value: 

2016 Value: 

2015 Value: 

2017 Quantity: 

2016 Quantity: 

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). 

VERSION 1 END 2 

Construction of MLCC

The information contained in this document is confidential and/or proprietary to Knowles Corporation and/or its affiliates. Please do not share this document or the information contained herein 

with anyone outside of Knowles Corporation or its affiliates, without first obtaining permission from an authorized representative of Knowles Corporation or its affiliates, as applicable. © 2016, 

Knowles Electronics, LLC, Itasca, IL USA. All Rights Reserved. Knowles and the logo are trademarks of Knowles Electronics, LLC. 1

BME vs PME Standard Termination

"i e rm i nation finis h plated wit h 

e iiher Ti n/ Lea d or 100% Ti n. 

Miold le laye r. Plated Nickel 

ba rri e r laye .-. 

Ceram ic 

Die lect,ic 

Interna l Electrod1e 

(Silve r, Pa lladlium) 

,Capaciilor oo,nstrud,io,n diagram of PME 

(St a nda rol termin ation) 

•< knowles 

Termination finicSh plated 

with either Tin/ Lead or 

100% Tin. 

M i.ddle layer. Pl'ated N rckel 

barrier l.aye1·. 

Base I aye,·. Coppe1· 

(sintered) 

Ceramic 

Dielectric: 

Internal El ed:rod e 

(Nickel) 

Capacitor construction diagram of BME 

(Standard termin ation) 
Construction of MLCC

The information contained in this document is confidential and/or proprietary to Knowles Corporation and/or its affiliates. Please do not share this document or the information contained herein 

with anyone outside of Knowles Corporation or its affiliates, without first obtaining permission from an authorized representative of Knowles Corporation or its affiliates, as applicable. © 2016, 

Knowles Electronics, LLC, Itasca, IL USA. All Rights Reserved. Knowles and the logo are trademarks of Knowles Electronics, LLC. 2

BME vs PME Flexible Termination 

Te.-mination fi nish plated with 

eithe r iri nJ Lead 01· 10 0% iri n , 

Mid dle layer. 

ban ie r la yer. 

Ba se la ye1·, Polyme,· 

C:eramic 

[lie lect,ic 

Interna l Electrode 

(Silve.-, Pa lladium) 

Capaciitor co:nstruct1io.n diagr-am of PME 

Fll exiCap"" (g oft t e,mi nallion) 

•< knowles 

Termination 

fin ish Tin 

Outer l a ye r 

IN ickel 

hanrie r layer 

Po1yma- Ceramic 

Dielectric 

Base Layer 

{Cu) 

In ne r 

Electrodes 

Ca paciilor cn:nstr11.1ction dia yr-am of BME Fl ex i cap TM 

(Soft term inatio11 ava ilabl e in X7 on ly) 

AFDOCS/17006810.1

TAPE AND REEL PACKAGING EXAMPLE:

BULK PACKAGING EXAMPLE:

• 

COMMERCIAL INVOICE 

DIS3PLEX FREE COMMERCIAL ZONE INVOICE#: 8289836 

AIRFREIGHT CARGO COMPLEX PAGE: Paoe 1 of 1 PENANG 11960 

Malaysia SHIP DATE: 24-SEP-18 

Phone: 6(04)-6147466 

KNOWLES /PC (M) SDN BHD 

NO 11, 49 and 51 JALAN BATU MAUNG 

l<NOWLES Fax: 6(04)-6437446 WAYBILL#: 

REG NO: 641240-U 

s KIMBALL ELECTRONICS GROUP B KIMBALL ELECTRONICS GROUP H Kimball Electronics US Broker I KIMBALL ELECTRONICS, INC. I L 

p Laredo Freight Dispatch L 1205 KIMBALL BLVD. 

9600 International Blvd. JASPER,47546 T Pharr.TX 78577 T UNITED STATES 

0 UNITED ST A TES 0 

IOR INCOTERMS FREIGHT TERMS SHIP METHOD WAYBILL 

CUSTOMER FCA ORIGIN COLLECT UPS Express Saver 

LINE# I ITEM DESCRIPTION I UOM I CUSTOMER PO I ORDER# I ORDER UNIT EXTENDED PRICE 

QTY PRICE 

3.1. 2225Y1K00704MXT Multi-Layered Ceramic EA 4502000760 5136710 6000 0.65800 $3.948.00 Capacitor 

CUSTOMER PART#: A-8794740MKP104M1C HTC: 8532.24.0020 COUNTRY OF ORIGIN: CHINA-CNKNOELE20SUZ 

ECCN EAR99 

Shipped Quantity Total: 6000 

Additional Shipment Information: 1 C(41 '21 '18CM) Total Net Weight: 1.854 KG 

Total Gross Weinht: 4 KG 

I DECLARE THAT ALL THE INFORMATION CONTAINED IN THIS IN2.0fEst·w~n,• CORRECT TOTAL USO$ $3,948.00 

" ------ Exchanae Rate 4.1002 

SIGNATURE OF SHIP XPORTER DATE Rinnnit Total 16,187.5896 ' 

Pr,nted on. 9.24,2018 11 31 AM 

•< l<nowles 

DI !•Johanson MFG•NovHc-.an°SvfP.r 0Vottronics 

October 2, 2018 

VIA REGULATIONS.GOV 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20508 

PUBLIC DOCUMENT 

Docket No. USTR-2018-0025 

Re: Request for Exclusion of Multilayer Ceramic Capacitors from the Determination of Action Pursuant 

to Section 301 

Dear Ambassador Lighthizer: 

Knowles Corporation ("Knowles") respectfully submits this request for exclusion of multilayer ceramic 

capacitors from the determination of action pursuant to Section 301 of the Trade Act of 1974.1 

Founded in 1946, Knowles has emerged as a market leader and global provider of audio and precision 

device solutions for the consumer electronics, hearing health, industrial and defense end markets. Our 

company delivers consistently dependable and precise products including hearing aid components, MEMS 

(micro-electro-mechanical systems) microphones, audio processors, and capacitors, which are supported 

by rigorous testing and research and development initiatives. We are headquartered in Itasca, Illinois, but 

employ more than 7,000 people in 11 countries worldwide. Our U.S. operations, including design centers in 

Cazenovia, New York and Valencia, California, produce groundbreaking technologies and employ 

approximately 600 hardworking Americans in its Precision Devices branch alone. Knowles also has 

additional operations in the United States for its audio businesses, which provides additional jobs. 

1 19 u.s.c. § 2411. 

2777 Route 20 East, Cazenovia NY 13035 

P (315) 655-8710 • F (315) 655-8179 • www.knowlescapacitors.com 

Quality Management System ISO 9001 and AS9100 Certified / Environmental System ISO 14001 Certified 
<nowles 

DI !•Johanson MFG•Novacan•Svfer•Voltronics 

This exclusion request addresses multilayer ceramic capacitors classified under HTSUS subheading 

8532.24.0020, which are currently subject to the 25% additional Section 301 tariff. Please note that a 

separate Section 301 Investigation Form to Request Exclusion of Product has been submitted for each 

dimension of multilayer ceramic capacitors for which we are requesting an exclusion. 

In accordance with the procedures released by the Office of the United States Trade Representative 

("USTR"), 2 Knowles provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China, i.e. whether the 

particular product and/or a comparable product is available 

from sources in the United States and/or in third countries. 

The multilayer ceramic capacitors that are the subject of this exclusion request are not produced in the 

United States and moving production to another third country is not feasible. The multilayer ceramic 

capacitors are part of our complete capacitor offering and are only produced in our facility in Suzhou, 

China. There is currently no alternative source for this Knowles-produced product. Moving production to a 

location outside of China would require significant time and resources, because Knowles would need to set 

up an entirely new production site. We estimate that such an endeavor would take approximately 6 to 12 

months. Additionally, the multilayer ceramic capacitors we produce in China have been qualified by our 

customers for use in their finished products. If Knowles were to move the production site, the capacitors 

would have to undergo extensive requalification and testing by our customers, which would take an 

additional 18-24 months. 

2 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 (USTR July 11, 2018). 

2777 Route 20 East, Cazenovia NY 13035 

P (315) 655-8710 • F (315) 655-8179 • www.knowlescapacitors.com 

Quality Management System ISO 9001 and AS9100 Certified I Environmental System ISO 14001 Certified 
significant harm

•< l<nowles 

DI l,Joh~nson MFG,Novar-,.n,Svfpr,Vnltrnn1r,s 

2. Whether the imposition of additional duties on the particular 

product would cause severe economic harm to the requester or 

other US interests. 

The Imposition of a 25% tariff on multilayer ceramic capacitors is causing severe economic harm to 

Knowles and other U.S. interests, including our downstream customers and, ultimately, American 

consumers. We estimate that the tariffs on multilayer ceramic capacitors will cause to our 

business, leading to a negative impact on our U.S. sales and profits and potentially leading to layoffs in the 

United States. The imposition of the 25% tariff on multilayer ceramic capacitors will place our U.S.-based 

company at a competitive disadvantage and will also likely result in lost business to foreign competitors. 

The multilayer ceramic capacitors at issue are used to filter signals in electronic circuits for various 

applications, such as wiring connectors for military and commercial aircrafts, military radios, and power 

supplies for military and commercial applications. Because there is no viable substitute for this product 

produced domestically, the 25% tariff functions merely as a penalty tax on U.S. companies selling to the 

military and industrial markets, which heavily depend on a stable supply of multilayer ceramic capacitors to 

produce these downstream products. Indeed, since many of the multilayer ceramic capacitors imported 

from China are used in military applications, the additional cost will also be passed through the supply 

chain to the U.S. government, leading to higher costs for this essential technology. 

3. Whether the particular product is strategically important or 

related to "Made in China 2025" or other Chinese industrial 

programs. 

The multilayer ceramic capacitors at issue are not strategically important to the "Made in China 2025" 

initiative, nor related to any other Chinese industrial program. Specifically, the capacitors are a lowertechnology product that is imported to support the production of higher-technology electronic circuits in the 

United States. The product is produced at Knowles' wholly-owned facility in Suzhou, China and shipped 

2777 Route 20 East, Cazenovia NY 13035 

P (315) 655-8710 • F (315) 655-8179 • www.knowlescapacitors.com 

Quality Managemait System ISO 900 I and AS9 l 00 Certified / Environmental System ISO I 400 I Certified 
•< l<nowles 

DI I• Johanson MFG•Novacan,SvfAr-Voltronics 

directly to our customers. The factory has no Chinese ownership and is the sole manufacturing site for 

these products within Knowles. There are no U.S. patents or trademarks covering this product and no 

intellectual property rights have been transferred to Chinese producers. In short, a tariff on this product 

does not accomplish the administration's goals of eliminating the Chinese policies, acts, and practices 

related to intellectual property. 

For the reasons set forth above, Knowles respectfully requests that multilayer ceramic capacitors classified 

under HTSUS 8532.24.0020 be excluded from the 25% Section 301 tariff. We appreciate the 

Department's consideration of this exclusion request. Please contact the undersigned if you have any 

questions regarding this submission. 

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

Respectfully. mitted, 

I 

1 _ I ~ 

1

~ stian Bell 

Vice President of Finance 

Knowles Precision Devices 

2777 Route 20 East, Cazenovia NY 13035 

P (315) 655-8710 • F (315) 655-8179 • www.knowlescapacitors.com 

Quality Management System ISO 9001 and AS9100 Certified/ Environmental System ISO 14001 Certified