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AFDOCS/17023963.1

October 3, 2018

VIA REGULATIONS.GOV PUBLIC DOCUMENT

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516

Washington, D.C., 20006 

Re: Request for Exclusion of Automotive A/C Compressors under 8414.30.8030 from the 

Determination of Action Pursuant to Section 301

Dear Ambassador Lighthizer:

Omega Environmental technologies Inc. (“Omega”) respectfully submits this request for 

exclusion of automotive A/C compressors from the proposed determination of action pursuant to 

Section 301 of the Trade Act of 1974.1 This request is timely filed, pursuant to the U.S. Trade 

Representative’s (“USTR”) instructions set form in the Section 301 Determination.2

Founded in 1989, Omega is recognized and respected as a leading U.S. distributor of 

aftermarket automotive, heavy duty truck, off-road, bus, and agricultural equipment air 

conditioning (“A/C”) products. We are headquartered in Irving, Texas, with additional 

operations in Georgia. Omega is principally engaged in the purchase and resale of automotive 

A/C parts, components, and systems. We carry a complete line of compressors, evaporators, 

 1 19 U.S.C. § 2411. 

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).
PUBLIC DOCUMENT Page 2

AFDOCS/17023963.1

condensers, expansion valves, receiver driers, hose, fitting and systems. 

Omega also designs and distributes engineered replacement parts for specialized 

automotive markets. Our products are both in international markets (principal markets include 

Canada, South America, the Middle East, Europe, and Mexico), as well as in the United States. 

Omega offers the following parts: accumulator/driers, blower assemblies, blower motors, 

compressors, condensers, electric fans, and fan accessories. We also carry electrical parts, 

evaporators, expansion valves, aluminum and steel fittings, heater control valves, heater fittings, 

convoluted tubing, sealing media, and specialty service kits. On February 8, 2017, Omega 

acquired the assets and assumed the liabilities of MEI corporation (“MEI”). As a result of this 

acquisition, the Company has expanded the product offering to include HVAC products for 

classes 6, 7 and 8 trucks and forestry, mining, and agricultural equipment. On November 6, 

2017, Omega acquired the assets and assumed the liabilities of TTA/C Air Conditioning & 

Heating Parts, Inc. (“TTA/C”). 

Omega Environmental Technologies is part of Omega Acquisition Corp. (“Omega 

Group”), which also includes Santech Industries, Global Parts Distributors, MEI, and Omega. 

Collectively we employ over 140 people, with warehouse space of over 250,000 square feet. We 

also own several patents for replacement small parts.

 This exclusion request addresses automotive A/C compressors classified under HTSUS 

subheading 8414.30.8030, which are currently subject to the 25% additional Section 301 tariff. 

The imposition of the tariff will negatively impact Omega’s U.S. operations, our U.S. 

employees, and our American customers. Please note that a separate Section 301 Investigation 

Form to Request Exclusion of Product has been submitted for each unique part number for which 

we are requesting an exclusion. 
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AFDOCS/17023963.1

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

Representative (“USTR”),3 Omega 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

Omega is not aware of any immediately available U.S. or third-country sources for the 

same or comparable products. Any supplier change would require a multi-year process to 

identify and establish a new source, complete testing, and obtain compliance approvals.

Omega has a vetted global supply chain that is the best option for sourcing its products 

and has allowed for continued growth thereby protecting American jobs. Any disruptions will 

result in serious inefficiencies and increase costs for our business and our customers. 

Additionally, the approval of a new product source would be very expensive and timely. 

An immediate change in sourcing would not only take years for testing and compliance 

purposes, but Omega would have to either complete its contracts or negotiate an exist from 

existing contracts. This would likely add significant time and expense to any effort to change 

sources. Omega estimates that a change in supplier would take approximately 5 years. Thus, no 

comparable products are immediately available. 

 3 Id.
PUBLIC DOCUMENT Page 4

AFDOCS/17023963.1

2. Whether the imposition of additional duties on the particular product would cause 

severe economic harm to the requester or other US interests

The products imported by Omega that are included on the USTR’s product list are air 

conditioning components that are sold in the United States directly (or incorporated into full A/C 

systems in the United States that are then sold) to warehouses, wholesalers, retailers, or A/C 

specialists working in the automotive, heavy duty truck, off-road, bus, and agricultural 

equipment vehicle aftermarkets. When sold in the aftermarket, these products allow consumers 

to make repairs and extend the use of these products. 

The imposition of a 25% tariff on these parts could cause severe economic harm to U.S. 

interests, including our employees and customers. As discussed above, the automotive A/C 

compressors at issue are incorporated into A/C systems used to cool automobiles, heavy duty 

trucks, off-road vehicles, buses and agricultural vehicles. Our products are sold directly to the 

users of such vehicles, many of which include small and medium-size U.S. businesses that 

depend upon our products to keep their equipment functioning properly. Additionally, a portion 

of our customers are downstream U.S. producers that require our products for U.S. 

manufacturing. 

If the additional tariffs are passed onto U.S. consumers through higher prices, Americans 

and small and medium-size U.S. businesses will be severely harmed. The requisite price 

increases would jeopardize their position in the marketplace and have substantial and lasting

negative effects on their sales and employment. If Omega directly absorbs the cost of the 

increase, our profitability will be damaged which would inhibit our ability to invest in U.S. 

facilities and American workforce training and development. 
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AFDOCS/17023963.1

Given the potential negative impact on Omega’s employees, customers, and U.S. 

businesses, we respectfully request that you grant this exclusion request.

3. Whether the particular product is strategically important or related to “Made in 

China 2025” or other Chinese industrial programs

The imposition of a 25% tariff on the subject automotive A/C compressors will not 

impact the Chinese intellectual property violations they seek to eliminate. Section 301 tariffs 

should be specifically targeted at products that have benefitted from the China’s acts, policies, 

and practices detailed in the USTR’s Section 301 Report. The automotive A/C compressors at 

issue have not benefited from China’s discriminatory licensing requirements, foreign ownership 

restrictions, state-funded acquisitions, or state-backed hacking operations. Omega has never 

transferred any intellectual property rights to Chinese producers and none of our company’s 

intellectual property is currently being used by a Chinese-owned facility. Indeed, the automotive 

A/C compressors at issue are produced exclusively for U.S. consumers and therefore do not 

contain Omega sensitive or proprietary information that the Chinese would be interested in 

misappropriating. 

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 
PUBLIC DOCUMENT Page 6 

AFDOCS/17023963.1

knowledge. 

 Contact 

Respectfully submitted, 

~~~/~ ~ 

Omega Environmental Technologies 

Inc.