Organization Name:

Note: Representatives submitting on behalf of an organization must enter information below.

Requestor Representative:

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.

3.

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

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential

information (BCI), is a public document, or is a public version of a BCI document.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

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

VERSION 1

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).

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

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:
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October 7, 2018 

VIA REGULATIONS.GOV PUBLIC

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 GPS Antenna: Parts # 513110-11860; #513110-11900; #513110-12010; 

#513110-12260; #513110-11821 and #513110-11811 from the Determination of Action Pursuant to 

Section 301 Tariffs 

Dear Ambassador Lighthizer, 

Aisin Electronics Illinois LLC (AEIL) respectfully submits this request for exclusion of this GPS 

Antenna from the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

World Corp. of America, our headquarters, is located in Northville Michigan. In addition, our research and 

development capabilities can be found throughout the United States. 

1

 19 U.S.C. § 2411. 
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AEIL manufactures electronic systems used to control products such as sunroofs, power sliding door 

systems, etc. (electronic parts). These parts are transferred to our customers, automotive OEMs in the United 

States to be assembled into vehicles. 

Our approach has always been to follow a global strategy and establish our family of companies in the 

U.S.to support the U.S. domestic and U.S. import manufacturer base. 

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid to long range, our 

strategy in the United States is to squarely focused on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customer. For AEIL this is an investment for the future we gladly make. 

The product we cite in this 301 exclusion request is purchased from China because it meets our 

engineering requirements. We are unaware of any other source, in the United States or abroad, which can 

supply the same product to our specific needs and those our OEM customers in the United States. 

We are constantly striving toward product improvement that will benefit consumers and its emphasis on 

environmental sustainability, community involvement and employee life balance, Aisin consistently lives up to 

its motto: “For a Better Tomorrow.” 

This exclusion request addresses our GPS Antenna classified under HTSUS subheading 8529104040 

which is currently subject to the 25% additional Section 301 tariff. The GPS Antenna is a Ceramic ‘Patch’ 

Antenna with a PCB Board protected by a plastic shield cover and mounted on a metal bracket. The PCB 

Board has a coaxial cable soldered to it and the cable has a connector that is connected to the GPS Head Unit. 
15300 Centennial Drive, Northville, MI 48168

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The metal bracket provides the electrical ground plane that is required for the GPS Antenna to correctly 

function. This GPS antenna is designed, developed and tested according to specific automotive customer 

specifications for the 440A program. 

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

(“USTR”),2 AEIL provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China. 

The customer specific GPS antennas is not available from any other sources in the United States or 

abroad for the following reasons: 

o The GPS antennas and their components are designed, developed and tested according to 

specific automotive customer specifications for each vehicle model type manufactured in 

North America. 

o The GPS antenna performance can be affected by location in the vehicle chassis in proximity 

to other devices and structural components. For this reason, each GPS antenna is custom 

designed to meet the automaker's specifications in their specific vehicle models. 

o The GPS antenna production line processes must be approved in advance by the individual 

automaker customer for production machinery, manpower, production methods, materials 

and measurement devices. 

o No other manufacturing locations outside of the China facility have been customer approved 

for these specific GPS antennas. 

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). 
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Therefore, The GPS antennas are unique for the automaker vehicle model for which they have been 

designed and no comparable GPS antenna can be used. The GPS antennas currently produced in China are not 

available from any other source in the US or abroad. 

In short, this product from China has met the final approval of our automotive partners and customers in 

the United States. The process to validate a new supplier will require extensive testing to validate the product, 

both for our purposes as well as our OEM customers. This testing, depending on the customer requirements and 

usually could take 12 to 18 months to complete which would jeopardize U.S. production schedules.. More 

importantly perhaps, as we noted above, there is significant risk involved with the quality and delivery aspects 

of this revalidation in terms of production schedules. 

This particular product, as specifically configured to our production needs, is not available outside of 

China. The company’s U.S. operations would suffer economically if we were forced to locate an alternative 

supplier as this would engender significant delay costs, requalification assessment costs, and potential loss of 

our OEM customer. In fact, any supplier change would require one year (or possibly more) to meet our 

customer approval demands. 

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

to the requester or other US interests. 

The GPS Antenna which is included on the USTR’s product list is a key component of our automotive 

parts manufacturing and is imported to support domestic manufacturing operations and American jobs in the 

United States. The imposition of a 25% tariff on these automotive parts could cause severe economic harm to 

U.S. interests, including our employees, our customers, and consumers, who eventually will be paying higher 

prices for new vehicles. Specifically, any future business opportunities involving these products could be 

directly impacted by the price increase caused by the additional tariff. Our concern here is that the 25% tariff 
15300 Centennial Drive, Northville, MI 48168

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will impact the company’s production costs, reducing profit margins and therefore minimizing any future R&D 

investments, in the long-run negatively impacting production strategy. This will, in turn, adversely affect a 

broader spectrum of U.S. interests, including U.S. investments, and jobs. 

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% ad valorem duty on the GPS Antenna from China will not impact the Chinese 

intellectual property violations they seek to eliminate. Section 301 tariffs are aimed at specifically targeted 

products that have benefitted from the China’s acts, policies, and practices detailed in the USTR’s Section 301 

Report. Made in China 2025 aims to promote their indigenous research and development capabilities. Our GPS 

Antenna is not a new technology. 

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 knowledge. 

Respectfully submitted, 

Larissa V. Koursova 

Assistant General Manager, Purchasing 

Aisin World Corp. of America 

Phone +1 734 582 7654 

Mobile +1 248 756 9958 

lkoursova@aisinworld.com