Section 301 Investigation: China's Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation - Form to Request Exclusion of Product 

..1,Vhen submitting a product exclusion request using this form, enter the specified 

inforrnation in the following fields and explain the basis and rationale for your statemen 

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 (BCH, Is a public 

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

Public Version of BCI 

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

Swivel Assembly. Please see part specification below. 

Length: 3.125 in 

Inner Diameter: 0.203 in 

Width: Varies (Assembled Part) 

Material: Aluminum 6061 - T6 

Seal: EPR 

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/ 

8479909496 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Anway, Karl 

Reelcraft Industries 

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

Requestor Representative: 

5. Requestor's relationship to the product: Importer 

6. Does this submission in regulations.govinclude 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. 

Public Version of BCI 

VERSION 1 CONTINUED BELOW 1 
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?: 

NO 

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: $35,468 2017 Quantity: 2,147 

2016 Value: $3Q066 2016 Quantity: 1,820 

2015 Value: $37,005 2015 Quantity: 2,240 

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). 

1. This product is only available from the existing source in China, an American-owned company operating in 

China which sells to Asian markets while also trading parts with its sister company in the United States. The 

design for this product is specific to the individual Bill of Materials of reels manufactured in America. It is not 

mass produced or readily available, and is in fact only traded through intra-company sales. 

2. The imposition of additional duties on this product would cause severe economic harm to Reelcraft 

Industries. An increase in duties essentially amounts to an increase in costs, which will impact our employees, 

customers, and community. This reduces our ability to increase wages for American workers, as well as 

provide the outstanding benefits that allow them to prosper and grow within the local comrnunity, boosting 

the local economy, and help to keep America the prosperous nation it is today. 

The increase In costs risks the possibility of a reduction in workers, a reduction in workers pay and benefits, 

or an increase in prices which would prompt customers to favor foreign competitors and become a loss for the 

American economy at large. 

3. This product is not related to "Made in China 2025" or other Chinese industrial programs to the best of our 

knowledge. This is a low-technology industrial component which represents no strategically important 

economic factor for our current trade relations. 

VERSION I END 2 
DESCRIPTION: RE NO. XXXXX 

30 FILENAME SHEET: 

I OF I 

300091 

FITTING ELBOW FITTING ELBOW 

OXYGEN 

ACETYLENE/ 

GAS 

260054 

SWIVEL STEM 

"A' 

(4 REO'D) 

300087 

RETAINING RING 

260055 

SW VEL BODY 

260056 

SWIVEL BODY 

300090 

PART NUMBER "A MATER AL LUBE TEST-PD-03 LABELS NOTES 

26005.7-I S314-14 260048 

260057-3 300095 260047/260048 

MATERIAL: 

ALUvINUM 

NO FINISH 

REDRAWN TO CHO 17756 MODEL NUMBER: 

VERIES LB. 

REV. DESCRIPTION/DATE ECN 

WEIGHT: 

SHEET SI2E: 

A 

AUTHOR: SCALE: 

AJS 

PROJECTION: ® 

THE PRODUCT SHALL NOT 

CONTAIN HEXAVALENT 

CHROMIUM IN CONCENTRATIONS 

ABOVE 0.1% WIN ON EACH 

HOMOGENOUS MATERIAL 

UNLESS OTHERWISE NOTED: 

DIMENSIONS ARE AFTER PLATING 

DIMENSIONS ARE IN INCHES. 

REMOVE BURRS, OXIDE SCALE, 

BREAK SHARP EDGES. 

CORNERS NOT TO EXCEED .015 

MACH. SURFACES ARE ViT5 MAX 

TOLERENCES (UNLESS NOTED): 

LENGTH ANGLE 

X t .5 X' ± 1' 

0.0 t .1 X.X' t .5' 

0.00 t .06 X.00' t .05' 

0.000 t .005 CONC.T.I.R .010 

SWIVEL ASSEMBLY 

260057-X