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A. The Product of Concern is Only Available from China

AC motors for use in Lafayette’s products are not available from U.S. suppliers and have not
been for at least 10 years. As part of efforts to remediate the impact of the 25% tariff GEA has
sought quotes from suppliers in other countries. Those discussions continue as issues of
capacity, quality and suitability for cooking appliance applications need to be resolved.
Alternatives supplies have not yet been qualified. The time to do so would take at least 12 to
18 months.

B. Imposing an Additional 25% Duty on The Product Will Cause Severe Economic
Harm to GE Appliances, its U.S. Employees and U.S. Consumers

The 25% tariff adds MM per AC motor. While this might seem to be a
manageable cost, the combined effect of that 25% on the several imported inputs used in the
manufacture of finished goods has a punishing impact on overall product cost that, for List 1
items alone, such ball bearings, stators & rotors, capacitors, resistors and controls could well
dF per appliance, which, if passed along by resellers to consumers could range
from . Recent research on consumer sensitivity to price changes found that price
increases as low as 4-7% would result in a 3-point drop in industry shipments. As noted above,
since only U.S. appliance producers would need to implement cost-recovering price increases,
the they would feel the full brunt of the share losses, which would reach double-digit levels.

This exclusion petition process offers the [lllemployees who manufacture GEA products
using AC motors and these other inputs the relief from the uncertainty that potential lost sales
would mean to the security of their employment.

C. The Products Are Not Strategically Important or Related the “Made in China
2025” Industrial Program

The mature nature of the technology of these products cannot advance the China 2025
industrial policy that the tariffs seek to challenge. And the critical role they play in sustaining
U.S. manufacturing, in keeping our U.S.-manufactured products competitive with foreign
exporters of finished refrigerators are additional reasons the Government should exclude these
water filters from tariffs under Section 301.

Moreover, granting this exclusion request will not undermine List 1 product coverage. Total US
imports from China in the pertinent 8-digit tariff code category during 2017 were valued at
~$5,908,000.00. In the alternative, should USTR elect not to exclude the entire 10-digit category but
only AC Motor, Multi-phase, Of An Output Exceeding 37.5 W But Not Exceeding 74.6 W to be
installed to drive fans in oven cavities not exceeding 7.5 cu.ft.

D. US Customs and Border Protection Agents Can Capably Administer This Exclusion
Request with Minimal Administrative Burden

HTSUS 8501.51.2040 covers AC motors for many applications. Entry documentation could
clearly describe and for Customs and Border Protection agents could inspect to confirm that
the motors as AC fan motors.


Company Certification of Confidential Business Information

GE Appliances (“GEA’”) is voluntarily providing this letter, the attached exhibits, and all other
information (collectively, the “submission”) concerning the product to the USTR. This
submission includes confidential, trade secret, commercial or financial information that GEA
would not customarily release to the public and disclosure of the information identified as
business confidential would endanger trade secrets or profitability and cause irreparable harm
to GEA. Pursuant to the USTR’s instructions in 83 Fed. Reg. 32183, business confidential
information is indicated by the use of brackets throughout this submission. GEA requests that
the USTR and its staff maintain the submission as confidential pursuant to all applicable laws
and regulations, including, without limitation, the Freedom of Information Act (“FOIA”). | certify
that | am authorized to make confidentiality claims of this sort on behalf of GEA.

Signature:

Name:

Date: October 9, 2018


They are used in various models of ovens and ranges to drive fans to evenly disperse heat in
conventional ovens and in convection ovens to speed cooking and browning, since
convection ovens blow more hot air over the surface of the food. Convection cooking has
gained in popularity as consumers have demanded speedier cooking.

Drawings of the AC motors used in in GEA ovens are attached as 1a and 1b.

I. About GE Appliances

GE Appliances (GEA) has manufactured major appliances in the United States for over a
century, first as a division of GE Company, and now, since the June 2016 acquisition, a Haier
company. We employ over 12,000 associates in the U.S., 9600 at in manufacturing-related
positions at plants in Louisville, Kentucky, Decatur, Alabama, Lafayette, Georgia. Selmer,
Tennessee and Camden, South Carolina. The remaining 2,500 are in sales, distribution and
other support functions. The company manufactures clothes washers and dryers,
refrigerators, cooktops, ovens, ranges and packaged terminal air conditioners for commercial
applications.

In addition to the 12,000 direct jobs, of GEA’s economic impact has resulted in creation of an
additional 30,000 jobs as a result of our investment in product development, manufacturing
machinery and equipment, purchased goods and services, and the salaries and benefits
earned by our employees. All told, GEA’s operations contribute $8.8 billion annually to national
GDP.!

Beginning in 2011, GEA set on a course significantly to increase the percentage of its
appliances manufactured in the U.S. by on-shoring manufacture of new products. New models
of refrigerators, clothes washers, dishwashers, water heaters, ovens and commercial air
conditioners were introduced during the following seven years. And, the degree of vertical
integration also accelerated.

In part, investment dollars were able to be redeployed to on-shoring and vertical integration by
cost-savings made possible by sourcing low-value, low-cost components from the global
supply chain, much of it located in China. That redeployment in turn has also fueled job
creation and promoted up-skilling of the workforce now focused on advanced manufacturing
tasks.

I. Rationale for the Exclusion Request

Several of the on-shored products manufactured in our Roper Corporation subsidia'
Lafayette, GA use the AC motors covered by this petition. More than

1 Source: Capital Policy Analytics, based on 2016 IMPLAN Economic Modeling System, October 2018. Authors:
Russell Kashian, Ph.D., Ike Brannon, Ph.D., Capital Policy Analytics, October 2018. All numbers are based on
2017.


IV. Conclusion

For these reasons, GEA respectfully requests that USTR grant this request and exclude the
Product of Concern from the additional ad valorem duty of 25%. Thank you for consideration of
this request.

Respectfully submitted,

(S2



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.

Public Version of BCI

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

See Attachment 1

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/

8501512040

4, Requestor Information

Requestor Name (Last, First): | Jones, Earl |

Organization Name: [GE Appliances, a Haier company ]

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.gov include additional attachments?

YES

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


Attachment 1a

Attachment 1b

NOT SUSCEPTIBLE TO PUBLIC SUMMARIZATION


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

INO.

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

YES

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: Business Confidential 2017 Quantity: Business Confidential
2016 Value: Business Confidential 2016 Quantity: Business Confidential
2015 Value: Business Confidential 2015 Quantity: Business Confidential
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).
See Attachment 1

VERSION 1 END



GE APPLIANCES
a Haier company

Public Version Business Confidential Information
Attachment 1
October 9, 2018
VIA Federal eRulemaking Portal

Hon. Robert E. Lighthizer

United States Trade Representative
600 17th St. NW

Washington, DC 20508

Attn: William L. Busis, Chair, Section 301 Committee

RE: 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

Docket No. USTR-2018-0025

Dear Ambassador Lighthizer:

GE Appliances, a Haier company, (“GEA”) respectfully submits this request for an exclusion
from the Section 301 tariffs on the following product described herein and listed in Annex B of
the USTR’s June 30, 2018 notice. 83 Fed. Reg. 28710:

AC Motor, Multiphase, Of An Output Exceeding 37.5 W But Not Exceeding 74.6 W,
Except Gearmotors. This product is classified under HTSUS 8501.51.2040.

These motors are installed in ovens to drive fans to more evenly distribute heat inside the
cooking caviy. They are manufactured A a
China.

In support of this request for exclusion of the Product of Concern from the Section 301
additional tariffs, GE Appliances states further as follows:

I. Description of the Product of Concern

The AC motors for which GEA seeks exclusion are weigh approximately 500g and made of
steel, ~50%, aluminum, ~20%, copper ~10%, polymer resins ~5%, 5% and contain lubricants...