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 

inforrnation 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: 

$pindle. Please see part specification below. 

Length: 6,522 in 

Outer Diameter: 2.050 in 

Inner Diameter: 1.648 in 

Base Plate: 3,250 in (circular) with 4x bolt holes of 0,313 in diameter 

Material: Aluminum 

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 itern number associated with your product, see https://hts.usitc.gov/ 

8479909496 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Anway, Karl 

Reelcraft Industries 

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.govinclude additional attachments? 

NO 

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

NO 

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

NO 

10, Please provide the value and quantity (with units) of the Chinese-origin product of concern 

that you purchased for each calendar year specified, Liinit 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: 2017 Quantity: 

2016 Value: 2016 Quantity: 

2015 Value: 2015 Quantity: 

11. Please provide information in support your request, taking account of the instructions 

provided in Section B of the Federal Register notke (note: text entered below can extend 

beyond the apparent size of this box). 

1. This product is only available from the existing source in China, an American-owned company operating in 

China which sells to Asian markets while also trading parts with its sister company in the United States. The 

design for this product is specific to the individual Bill of Materials of reels manufactured in America. It is not 

mass produced or readily available, and is in fact only traded through intra-company sales. 

This product also requires tooling which represents a substantial cost, and would require several months 

worth of design and manufacturing before a domestic source could be obtained. 

1 The imposition of additional duties on this product would cause severe economic harm to Reelcraft 

Industries. An increase in duties essentially amounts to an increase in costs, which will impact our employees, 

customers, and community. This reduces our ability to increase wages for American workers, as well as 

provide the outstanding benefits that allow them to prosper and grow within the local community, boosting 

the local economy, and help to keep America the prosperous nation it is today. 

The increase in costs risks the possibility of a reduction in workers, a reduction in worker& pay and benefits, 

or an increase in prices which would prompt customers to favor foreign competitors and become a loss for the 

American economy at large. 

3. This product is not related to "Made in China 2025 or other Chinese industrial programs to the best of our 

knowledge. This is a low-technology industrial component which represents no strategically important 

economic factor for our current trade relations. 

VERSION 1 END 2 
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