PRESTO* 

National Presto Industries, Inc. 

Eau Claire, WI 54703-3703 

October 3, 2018 

Via regulations.gov 0% 

wwwgopresto.com 

Tel. 715-839-2121 

Fax 715-839-2148 

715-839-2122 

715-839-2242 

Re: Request for Exclusion from National Presto Industries, Inc. for Vent Pipe With 

Nut Service Part Classified as HTSUS 8481.40.0000 

National Presto Industries, Inc. ("NPI") is writing to express its deep concern with the Office 

of the United States Trade Representative's (USTR) proposal to use a 25% tariff increase to 

address China's unfair trade practices and its trade investment relationship with the United 

States. As explained in more detail below, NPI requests an exclusion from the tariff increase 

for its vent pipe with nut service part, which has a 10-digit HTSUS classification of 

8481.40.0000. The internal Service Number is 85735. 

Request for Exclusion of Service Parts 

a) 10 Digit Subheading of the HTSUS Most Applicable to the Service Part 

HTSUS 8481.40.0000 

b) Identification of the Particular Physical Characteristics of the Service Part and 

How They Are Distinguishable From Other Products Coded 8481.10.00 

The 8-digit subheading HTSUS 8481.40.00 covers "safety or relief valves for 

pipes, boiler shells, tanks, vats or the like." The service parts requested for 

exclusion by NPI are therefore distinguishable from other products within the 

covered 8-digit subheading 8481.10.00 in that they are used as service parts for 

small consumer household appliances, specifically pressure cookers. Pipes, 

boiler shells, tanks and vats are not consumer household products. 

The service part at issue is comprised of a vent pipe and a nut. The vent pipe has 

an internal Part Number of 29-214. The vent pipe has a diameter of 0.44 inches; 

a height of 1.17 inches; and a weight of less than 0.1 pounds. The material 

composition is brass. 

The nut has an internal Part Number of 25-009. The nut has a diameter of 0.43 

inches; a height of 0.56 inches; and a weight of less than 0.1 pounds. The 

material composition is stainless steel. 

c) Annual Quantity and Value of Service Parts Purchased Last Three Years 

• 2015- Quantity: 12 Value: $54.00 

• 2016- Quantity: 8 Value: $36.00 

• 2017- Quantity: 13 Value: $58.50 

d) These Service Parts Are Only Available from China 

The service parts requested for exclusion are only available in China. These parts 

are critical for the safe operation of the cookers. The best way to assure that the 

Trademark of National Presto Industries, Inc. 

8804520 
parts meet specification is to have them manufactured on the same tooling that is 

used to manufacture the actual cookers. The demand for the impacted parts is 

such that it would not be feasible to tool or print those parts in the United States. 

e) Increasing the Tariff on These Service Parts Will Have No Impact on the Trade 

Deficit 

An increased tariff on NPI's service parts and small consumer appliances will 

have no impact on the trade deficit, but would increase the price of the part to the 

consumer. If the tariff goes through, NPI will continue to import the service parts 

into the U.S. as long as there is a consumer demand to pay the higher price. If 

demand from consumers after the price increase drops to the point that offering 

the part is no longer feasible, the part will be discontinued. Given the dollars 

involved, discontinuance of this service part will have no impact on the trade 

deficit. 

0 These Service Parts Have No Strategic Importance to the Made in China 2025 

Program 

Stated simply, there is absolutely no correlation between the proposed tariffs on 

these service parts for pressure cookers and the Made in China 2025 Program. 

Made in China 2025 is Beijing's plan to transform China into a hi-tech 

powerhouse that dominates advanced industries like robotics, advanced 

information technology, aviation, and new energy vehicles. 

Service parts for pressure cookers have no strategic importance to that Made 

in China 2025 Program. The Chinese are not interested in any intellectual 

property or technological innovations relating to these service parts because the 

technology is dated. These parts have been features in pressure cookers since 

NPI introduced the first pressure cooker using a rotating lid and gasket during the 

World's Fair in 1939. There are simply no innovations or technological advances 

to be made relating to these service parts. 

For the reasons stated above, NPI requests an exclusion from the tariff increase for its vent 

pipe with nut service parts, which have a ten-digit HTSUS classification of 8481.40.0000. I 

certify that the information provided herein is complete and correct to the best of my 

knowledge. 

Respectfully Submitted, 

Pete Furrer 

Associate Corporate Counsel