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

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

When submitting a product exclusion request using this form, enter the specified 

informationinthefollowingfieldsandexplainthebasisandrationaleforyourstatements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge.

1. Indicatewhetherthe comment containsbusiness confidentialinformation(BCI),is apublic

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

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

3. 10-digitHTSUSitemnumber*forproductyouwishtoaddressinthisproductexclusionrequest:

*Usenumerical characters onlywith no special characters (example: 1023456789).Forhelpinfinding

the HTSUS itemnumber associated with your product, see https://hts.usitc.gov/

8525.60.1030

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 theproduct:

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

7. Pleaseindicatewhetheranyadditionalattachment containsbusiness confidential

information (BCI), is a public document, oris a public version of a BCI document.

No

Public Version

The requested exclusion is for VHF two-way radios designed for marine applications. The specific 

Cobra-brand model at issue is MR HH125, which is a 3-watt, hand-held marine radio. The unit is 

composed of plastic, steel, aluminum and electronic components. Detailed product specifications, 

including dimensions, are attached.

No

Linda J. Engell, V.P. Supply Chain & Operations

Cedar Electronics Corporation

Importer

Barnes, Richardson & Colburn – Lawrence M. Friedman
8. Is thisproduct, or a comparableproduct, available fromsources intheUnitedStates?:

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

10. Pleaseprovide thevalue andquantity (withunits) oftheChinese-originproductof concern 

thatyoupurchasedforeachcalendaryearspecified.Limitthis figuretotheproducts 

purchased by your firm (or by members of your trade association) alone. Please provide 

estimates if precise figures are unavailable.

2015 2016 2017 2018 (Est.)

Units [Table Redacted]

Dollars

11. Please provide information in support yourrequest, taking account ofthe instructions 

provided in Section Bofthe Federal Register notice (note:text entered below can extend 

beyond the apparent size of this box).

No

Yes
The Cobra radio brand dates back to 1963 when Dynascan, the predecessor company, brought its first CB 

radios to the marketplace. After diversifying into other products including radar detectors, police 

scanners, cordless phones and answering machines, Cobra entered the marine radio and navigation market 

in 2003. Cobra is now a brand of Cedar Electronics, which also produces a full line of dash cameras and 

power accessories. Cedar has 141 employees in the United States in its Chicago, Illinois and West 

Chester, Ohio locations. These U. S.-based employees include manufacturing support and engineering for 

the design and development of new products including marine radios and CB radios integrated via 

Bluetooth with smartphones. 

Severe Economic Harm 

Because there are no manufacturers of marine radios in the U.S., the current 25% duty creates a 

significant competitive disadvantage for Cobra. Cobra estimates an annual cost of 

]. Our contribution margin is [ ]. Absorbing the 

additional cost would [ ]. Ninety-five percent of 

boats in the U.S. are small, towable vessels under 26 feet in length. Seventy-two percent of boaters in the 

U.S. have an annual household income of less than one hundred thousand dollars ($100,000). Based on 

these figures, the majority of customers for Cobra's marine radios are working class individuals 

purchasing a necessary safety device. As a result of these duties, these individuals will see the cost of 

Cobra safety equipment increase. Faced with that reality, Cobra's customers will probably stop buying the 

"American" brands available to them to instead buy the cheaper Japanese product. 

Available Source Countries 

Marine band radios are manufactured in China, Japan and Vietnam. They are manufactured using a 

mature technology with no alternative use, as such, it is unlikely that a company will invest in establishing 

a manufacturing facility to create these products. Cobra is the market leader with a [ ] market share in 

North America for vessels at or below 30 feet in length. Cobra's main competitors are: 

Company Headquarters Manufacturing Est Market Share

Uniden Japan Vietnam 21%

Icom Japan Japan 11%

Raymarine United Kingdom China 4% 

Simrad Norway China 2%

Standard Horizon USA China 23%

Garmin USA China 5%

All U.S.-based marine radio companies are manufacturing in China. Therefore, all U.S. manufacturers 

will be negatively impacted by this duty with a correlating benefit to the Japanese companies. 

Made in China 2025 

While Cobra continues to innovate, marine band radios are a mature technology that is critical for the 

safety and communications of boaters nationwide. There is no indication that short-range, mobile radio 

transceivers have or will benefit from China's policies relating to intellectual property rights and 

technology transfer. Marine band radios are not part of the Made in China 2025 initiative. These products 

have no application to cloud computing, the Internet of Things, autonomous vehicles, agricultural 

equipment, semiconductors, and battery technology. Thus, removing marine band radios from the list of 

items subject to the 301 duties does not further the interests and policies these duties are intended to 

combat. 

Ease of CBP Administration

These products are labeled and invoiced as marine VHF radios. Thus, they are easily distinguishable 

among products in this 8-digit classification. 
3 Watt VHF

Select between 1 and 3 Watts 

for small boats and personal 

water craft.

Large LCD screen

Large and bright LCD screen 

for easy viewing.

All NOAA weather channels

Instant access to national 

all hazards and weather 

information, 24 hours a day.

Waterproof

Designed to JIS4 standards.

Belt Clip

Easy to operate spring loaded 

belt clip.

COMPACT VHF RADIO 

MRHH125_SPEC.indd 1 7/31/09 1:
 Number of Channels All: U.S.A., Canadian, 

International

10 NOAA Weather Channels

 Channel Spacing 25 kHZ

Modulation 5 kHz Max.

Input Voltage 6.0 VDC

Battery Life: 

5% TX, 5% RX, 90% Standby

Current Drain:

 Stand-by 40 mA

 Receive 100 mA

 Transmit 1.1 mA @ High Power

700 mA @ Low Power

Temperature Range -20oC to 50oC

Unit Dimensions 4.0” x 2.4” x 1.2”

(102 mm x 62 mm x 31 mm)

not including antenna

Unit Weight (Lbs) 0 lbs., 5 oz. (228 g.) 

without batteries

Receiver

Frequency Range 156.025 to 163.275 MHz

Receiver Type Double Conversion 

Super-Heterodyne

Sensitivity:

 20 dB Quieting 0.35 uV

 12 dB Sinad 0.30 uV

Squelch Sensitivity (Threshold) 0.20 uV

Adjacent Channel Selectivity -60 dB

Intermodulation and Rejection -60 dB

Spurious & Image Rejection -60 dB

AF Output 250 mW @ 8 Ohms

Transmitter

Frequency Range 156.025 to 157.425 MHz

RF Output Power 1 or 3 Watts 

Spurious Emissions -60 dB @ High Power

-55 dB @ Low Power

Microphone Type Electret

Microphone Impedance 2.2 K Ohms

Frequency Stability +/-10 ppm

FM Hum & Noise 40 dB

Packaging Specifi cations

Individual Clam/ 11.50” H x 8.00” W x 3.25” D

Box Dimensions (292 mm x 203 mm x 83 mm)

Individual Clam/Box Weight 0 lbs., 12.8 oz. (363 g.)

Master Pack Qty. 4

Master Pack Dimensions 11.9” H x 8.50” W x 6.9” D

(302 mm x 216 mm x 175 mm

Master Pack Weight 4.0 lbs., 0 oz. (1814 g.)

SKU # MR HH125

UPC # 028377 20122 6

Nothing Comes Close to a Cobra® MRHH125 SP 07/09

Cobra®, CobraMarine®, Nothing Comes Close to a Cobra®, and the snake design are registered trademarks of Cobra Electronics Corporation, USA. 

Cobra Electronics CorporationTM is a trademark of Cobra Electronics Corporation, USA.

©2009 Cobra Electronics Corporation, 6500 West Cortland Street, Chicago, IL 60707, USA

Features Benefi ts

Included Accessories

Unit Specifi cations

General

NiMH: 

9.4 Hours @ 3 Watts 

26 Hours @ 1 Watts

Alkaline: 

12 Hours @ 3 Watts 

33 Hours @ 1 Watt

 1 or 3 Watts Dual output power for short and long communication.

U.S.A., Canada & International Channels Allows operation on any of the three (3) different channel maps 

established for these areas.

10 NOAA Weather Channels Instant access to national all hazards and weather information, 24 hours a day.

Weather Alert Alerts with an audible tone and visual alarm if threatening weather is nearby.

Instant Channel 16 and 9 Instant access to channel 16 and 9 for emergency situations.

Scan Scan all channels to  nd conversations in progress.

Signal Strength Meter Shows the strength of outgoing and/or incoming signal.

Button/Key Lock Locks function buttons/keys to eliminate accidental change of settings. 

Battery Charge Jack Allows charging of batteries in unit.

Illuminated LCD Display and Keys Allows high visibility of display and keys at night.

Speaker/Microphone Jack Allows connection of hands-free accessories. (Single pin connection)

Waterproof Waterproof to JIS4 standards; splashproof.

1 Year Warranty (on radio) For products sold in the U.S.A.

5 850 mAh AAA NiMH Provides extended operating time compared to alkaline batteries with no 

Rechargeable Batteries memory effect. Also works with standard alkaline batteries (not included).

12 Volt Accessory Charger Allows charging of batteries in unit using standard jack.

Spring Loaded Belt Clip Secures the radio while on the go. Easily locks in place.

Wrist Strap For ease of carrying and securing while on the go.

TM

MRHH125_SPEC.indd 2 7/31/09 1: