Monday, October 1st, 2018

Ambassador Robert E. Lighthizer

U.S. Trade Representative

Office of the United States Trade

Representative

600 17th Street NW

Washington, DC 20006

Re: USTR-2018-0025 – Procedures to Consider Requests for Exclusion of 

Particular Products from the Determination of Action Pursuant to Section 

301: Needle roller bearings (SUJ2 steel) consisting of inner and outer rings, a 

cage or retainer, a seal, and steel needle rollers that do not exceed 5mm in 

diameter and are at least three times the diameter in length. (HTS# 8482.40.0000)

Dear Ambassador Lighthizer:

NSK Americas, Inc. and its US subsidiaries are designers, engineers, and manufacturers 

of advanced motion and control technologies that includes anti-friction bearings, steering 

columns, bearing components, and precision products for supply to key US industrial and 

automotive customers and for export outside the US. We employ over 2,400 people in the US in 

design, engineering, manufacturing, technology, financial, and other capacities. Annually we 

invest in excess of $25 million expanding and enhancing our US businesses.

The subject material that is of Chinese origin is not presently available domestically.

These bearings are specifically designed and made for applications in the production of our US 

produced steering columns which are a safety critical application of a vehicle. As such, any

premature or forced change in design, material, or process (including new source or location) 

without adequate planning could have severe ramifications related to the performance of a 

vehicle. Attempting to move these parts to another source would require additional extensive 
testing, validation, and approvals costing our company upwards of $1 million and a minimum of 

6 months to 1.5+ years, by which time the platform or program these units are used in may end 

production.

NSK sourced from China due to cost competitiveness. This required NSK's steering

business to find an overseas supplier to help support the higher volumes and unique production 

requirements at a competitive market cost for our niche OEM customers in this highly 

competitive business segment. As a result, the imposition of Section 301 duties has a direct, 

immediate, and severe impact to our company. NSK Americas has absorbed costs from 

previously implemented tariffs which has affected both sales and profitability of our steering 

division. NSK has passed on a portion of the tariff cost to our customers which will eventually 

hurt the ultimate end user - the individual consumer.

We are also not aware of any impact the production of the subject bearing rings have had

as it relates to the "Made in China 2025" initiative or any other Chinese industrial based 

program. This is due to the fact that bearing design and development, along with their respective 

sub components, have been traditionally considered low-tech.

Please note that to our knowledge, NSK has not been harmed by any China policies 

and/or practices as it relates to Intellectual Property Rights, including the transfer of technology. 

Moreover, anti-dumping on majority of bearings and its respective sub-components was removed 

as recently as mid-2014 when USITC ruled anti-friction bearings were not being sold below US 

market value, further justifying the exclusion of any type of additional duties.
NSK is unaware of any potential issues that would affect the ability of US CBP to 

administer subject exclusion. CBP should be able to easily identify the products based on 

HTSUS code, MID, and country of origin.

As such, we respectfully request exclusion from Section 301 for our product classified 

under HTS# 8482.40.0000, which is produced and sourced from China.

Sincerely,

Steven A. Beckman

NSK Americas, Inc. 

Chief Executive Officer 

beckmas@nsk-corp.com

(734) 913-7500