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October 9, 2018 

VIA ELECTRONIC FILING PUBLIC VERSION 

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

United States Trade Representative 

Office of the United States Trade Representative 

600 17th St. NW 

Washington, DC 20508 

Re: Request for Exclusion from Section 301 Tariffs of Certain Mold Components 

Dear Ambassador Lighthizer: 

 

On behalf of our client, Milacron LLC and its subsidiary, DME (collectively “Milacron”), we 

hereby submit our exclusion request for certain mold components from the Section 301 tariffs 

enacted against products from the People’s Republic of China (“China”). These products have 

limited availability outside of China; none of which are identified in the “made in China 2025” 

program; and imposition of additional duties on these products would significantly undermine 

Milacron’s competitive advantage in both the U.S. and global market. 

For these reasons, Milacron respectfully requests that mold components imported from China, 

classified under HTS 8477.90.8501 be excluded from the final section 301 tariff list. 

A detailed list of Milacron imported mold components are provided herein: 

I. Background 

Milacron is a global leader in the manufacture, distribution and service of highly engineered and 

customized systems within the $27 billion plastic technology and processing industry. Milacron 

is the only global company with a full-line product portfolio that includes hot runner systems, 

injection molding, blow molding and extrusion equipment. We maintain strong market positions 

Identifier Product Description Part Number Net Weight (kg) Length (mm) Width (mm) Height (mm)

Core Pins Various Various Various Various Various

Ejector Pins Various Various Various Various Various

Leader Pins Various Various Various Various Various

Hot Runner Assembly Parts Various Various Various Various Various

Slide Interlocks Various Various Various Various Various

Slice Lock Sets Various Various Various Various Various

Support Pillars Various Various Various Various Various

Misc. Mold Components Various Various Various Various Various
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across these products, as well as leading positions in process control systems, mold bases and 

components, maintenance, repair and operating (“MRO”) supplies for plastic processing 

equipment and fluid technology. Our strategy is to deliver highly customized equipment, 

components and service to our customers throughout the lifecycle of their plastic processing 

technology systems. 

Milacron services a diverse range of industries and have longstanding relationships with many of 

our over 27,000 customers and leading market shares in North America, and in emerging 

markets, including China and India. 

Milacron has over 150 sales and manufacturing facilities globally (14 USA locations including 

Milacron’s largest manufacturing facility in Batavia, OH), with products sold in over 100 

countries across 6 continents. 

Milacron’s business segments annually source $500-$550 million worth of materials for our 

various product offerings from over 8,000 suppliers globally. The China based supplier account 

for less than 5% of the total global suppliers in number, but represents an estimated 15-20% of 

Milacron’s $500-$550 million annual material purchase in value. 

II. Mold Components Have Limited Availability Outside of China 

Milacron’s DME Company subsidiary (DME) sources various mold components from suppliers 

in the U.S. and globally. These mold components are classified under U.S. HTS code 

8477.90.8501. DME is unable to source mold components grouped under core pins, ejector pins, 

leader pins, hot runner assembly parts, slide interlocks, slide lock sets, support pillars, and 

related components (hereafter referenced as ‘Mold Components’) from U.S. suppliers. 

The attached import data shows that more than 80% of imports to the U.S. of mold components 

are sourced from China, which is approximately five times more than imports from all other 

countries combined. No other country can produce the mold components needed for industrial 

requirements, the quality demanded by DME, and no U.S. supplier has been identified that can 

produce the specific mold components DME requires. U.S. manufacturers previously produced 

DME required mold components, but these manufacturers subsequently have gone out of 

business. China is the main international source that is able to supply the U.S. market in 

meaningful commercial quantities, and China suppliers can and do produce the mold 

components DME requires. 

Even if DME was able to find alternative suppliers, sourcing outside of China is extremely risky 

and costly. DME has invested significant time and capital to build very strong business 

relationships with its Chinese suppliers, and these relationships are difficult to immediately 

replicate. Thus, DME’s supply chains cannot be shifted to different countries or facilities without 

compromising long term contracts, compliance to standards, and quality and value for mold 

components. The proposed incremental Section 301 tariffs will force DME to search for and 

qualify non-Chinese manufacturers in countries where the capacity to produce these products at a 

high quality level has not yet been fully identified or developed. 
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III. Additional Section 301 Tariff Will Drive up Costs and Impede DME’s Ability to 

Compete on an International Scale 

DME currently holds competitive advantage in the manufacturing and distribution of mold 

components on two fronts: advanced technology and cost efficiency. While DME has created 

competitive advantage mainly by achieving a superior quality and performance, DME also 

strives to keep a lower cost structure when competing with its competitors. To do this, DME 

relies on the quality and the availability of mold components and services supplied by upstream 

actors, such as mold component suppliers, to respond to customers’ demands and help lower 

costs. 

DME focuses on the operations which generate the highest added value and profitability from 

machine tools and molds. DME sourcing of mold components for specific requirements, which 

required lengthy research, engineering and development efforts. Mold components represents 

about [--------] of DME’s product costs. There are no domestic sources for DME’s required mold 

components and global capacity is significantly constrained leading to already high costs and 

long lead times. Any additional duty on such mold components — let alone a 25% percent duty -

- would cause DME major financial harm and jeopardize DME’s ability to satisfy its contractual 

obligations to its downstream customers. 

In addition, escalated operating costs due to Section 301 tariffs on mold components would make 

DME less competitive on the international market. DME is one of the United States’ major 

producers and exporters of mold components to emerging industrialized markets. In 2015, U.S. 

producers exported over $8.1 billion worth of machinery to industrial end-users in markets 

around the world. It is estimated that exports of machines, machine tools, and mold components 

will rise at a strong annual rate. 

DME operates in global markets where competitors outside the United States will use the same 

mold components and manufacture outside the United States, and then import the finished 

products into the United States and emerging markets – all without tariffs while directly 

competing with U.S. manufacturing. When DME sells mold components for use in machines and 

machine tools in the United States and/or other countries, DME will do so with a higher cost 

structure than DME’s competitors producing outside the United States. This will place DME at a 

competitive disadvantage both in the United States and in DME’s export markets. In turn, this 

will only increase the incentive to move production and jobs out of the United States in order to 

remain competitive and place U.S. manufacturing at risk. 

IV. Additional Tariffs Would Have Adverse Impact on U.S. Economy and National 

Security Interest 

Mold components used in machines and machine tools incorporated with Chinese parts are 

cornerstones for automotive, aerospace, medical, home appliance, construction, and other heavy 

industries. They are used in the production of crucial mechanical parts and components such as 

bodies, engines, gear boxes and powertrains for the automotive industry; the production of high 

precision 3D parts for the aerospace sector; and for manufacturing high precision implants, 

surgical instruments and precision components for the medical engineering industry. Mold 
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components and machine tool consumption in the United States totaled $8.142 billion in 2017, 

an increase of 6.8 percent from 2016. A robust domestic manufacturing industry for mold 

components used for machine tools is critical to the U.S. economy. 

Because the mold component / machine tool industry is a technology-intensive sector, it requires 

the employment of a highly skilled workforce. Such a workforce includes workers with degrees 

in engineering, software development, electronics, and mechanical processes in order to provide 

service to customers or to engage in R&D. Allowing mold components to be excluded from 

Section 301 will create a significant opportunity to retain and add such highly skilled jobs in the 

U.S. throughout the supply chain. These are the types of jobs the United States needs to protect. 

Finally, machines and machine tools built using DME mold components are important for U.S. 

national security because they are used to manufacture defense articles such as aircraft, armor, 

weapons, munitions, vehicles, and heavy equipment for the armed forces. In 1983, the National 

Machine Tool Builders’ Association filed a petition with the Secretary of Commerce under 

Section 232 of the Trade Expansion Act of 1962 requesting quotas on certain U.S. imports of 

metalworking machine tools. The Secretary made an affirmative finding that imported machine 

tools threaten to impair U.S. national security. After considering mobilization, defense, and 

economic planning factors, the President announced in 1996, that voluntary restraining 

agreements would be sought with Japan, Taiwan, West Germany, and Switzerland. The President 

also announced the implementation of the Machine Tool Domestic Action Plan to support the 

revitalization of the U.S. metalworking machine tool industry. Milacron responded to this action 

by expanding R&D and U.S. production of machines and machine tools with sourcing basic 

components such as cast iron only. If additional Section 301 tariffs are imposed, it would 

adversely impact how much U.S. machine tool builders, including Milacron and DME, would 

spend on capital, on R&D, and on production in the United States. This would significantly 

impact the ability of the United States to remain ahead in the, machine building, aerospace and 

other defense-related industries, as there are no companies within the U.S. producing mold 

components that can be incorporated into machine tools. 

V. The Mold Components are Not Identified in “Made in China 2025” Plan 

Milacron and DME invests significantly in the machine tool and mold component industry and 

understands the administration’s goal of protecting the intellectual property rights and trade 

secrets of U.S. companies operating in China; however, imposing Section 301 tariffs on mold 

components from China would not be practicable or effective to eliminate China's unreasonable 

and discriminatory acts, policies, and practices identified by USTR in its report in this 

investigation. The machine tool and mold component industry is a technical and technologyintensive sector. Innovation and capitalizing on knowledge-intensive, high value activities are 

the only way for DME to remain competitive in global markets. However, mold components 

play no role in the innovation of machine tools. Mold components are not part of the “Made in 

China 2025” Plan. Indeed, the Chinese plan aims at developing the following advanced products 

and parts: 

1). Major products: 

a. Electronic information processing equipment: Focus on the development of 
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20000 ~ 60000 r / min high-speed drilling center, five-axis linkage high-speed 

machining center, PSA paste machine and robotic assembly and inspection lines. 

b. Aerospace large structural parts manufacturing and assembly equipment: 

Focus on the processing of aluminum, magnesium, titanium, high-temperature 

alloy and other sophisticated materials with the application of multi-axis linkage 

gantry CNC milling machine, five-coordinate mirroring machine tool, robot 

cluster automatic drilling riveting, composite material automatic laying/sanding, 

multi-dimensional friction welding, super plastic/diffusion forming, precision 

controlled heat treatment, structural fatigue and bearing capacity test equipment, 

large aircraft and large rocket digital assembly. 

c. Key equipment for aero engine manufacturing: Focus on the development of 

horizontal machining centers, turning and milling centers, boring machines, 

internal and external grinding machines, heavy-duty inertia friction welding, 

rolling forming, single crystal casting, high temperature vacuum heat treatment, 

surface strengthening, laser microporous forming equipment for key components 

such as blades, impellers, turbine disks, casings, and spindles. 

d. Key manufacturing equipment for marine and offshore engineering equipment: 

Key development of ship and offshore high-strength steel sheet single-sided 

welding double-sided forming (FCB), curved segment flexible support, highpower laser hybrid welding, multi-point pressure forming and other plane and 

curved segmentation line critical equipment; large diesel engine block, crankshaft 

, advanced processing and forming equipment such as gears, blades and offshore 

racks; and water-deep welding equipment with a depth of more than 1000 meters. 

e. Complete set of processing equipment for key components of rail transit 

equipment: Focus on the development of high-efficiency laser/stirred friction 

welding equipment for aluminum-magnesium alloy/stainless steel body, core 

manufacturing equipment for 30-ton axle heavy-duty electric locomotive, mobile 

high-speed welding equipment above 120Km/h, gears for trains with speeds 

above 350Km/h, lightweight machining and forming equipment such as bearings, 

wheel sets, bogies, and brake systems. 

f. Automobile key parts processing equipment and production line: Focus on the 

development of high-efficiency machining/near-net forming equipment and group 

production lines for automobile engines/gearboxes; development of diesel highpressure common rail, automotive safety, low-cost ultra-high-strength 

steel/aluminum alloy/carbon fiber automotive parts; and new energy vehicle 

electromechanical coupling systems, efficient processing and forming, on-line 

inspection and assembly equipment. 

g. Automobile four major process assembly line: For medium and high-end 

models, focusing on the application of ultra-high-strength steel/aluminum 

alloy/carbon fiber lightweight high-strength materials; development of 
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lightweight hybrid materials, servo stamping/molding based on domestic robots, 

and efficient connection (laser welding, riveting, bonding) ), environment friendly 

energy-saving coating, digital robot assembly and other production lines. 

h. Large-capacity power equipment manufacturing equipment: Focus on the 

development of high-quality casting of millions of kilowatt-class nuclear power 

main pumps, complete sets of gas turbine welding rotor manufacturing 

equipment, robot welding complete sets of millions of kilowatt turbines, precision 

manufacturing equipment for ultra-high voltage power transmission and 

transformation equipment, and digital assembly equipment. 

i. Engineering and agricultural machinery production line: Focus on precision 

machining equipment and complete production lines for engineering and 

agricultural machinery engines, gearboxes, high-pressure and high-flow hydraulic 

systems, as well as robot-based production lines for welding, painting and 

assembly. 

2). Additive manufacturing equipment: Focus on breaking through the highefficiency additive manufacturing process, complete sets of equipment, special 

materials and engineering key technologies of high-performance large-scale key 

components such as titanium alloy, high-strength alloy steel, high-strength 

aluminum alloy, high-temperature alloy, non-metal engineering materials and 

composite materials. Develop laser, electron beam, ion beam and other energydriven mainstream process equipment; overcome bottlenecks such as material 

preparation, print heads, and intelligent software to build an industrial chain. 

3). High-grade CNC system: Focus on the development of multi-axis, multichannel, high-precision interpolation, dynamic compensation and intelligent 

programming, intelligent CNC system with self-monitoring, maintenance, 

optimization, reorganization, etc.; provide standardized basic platform, allowing 

developers, different software and hardware modules intervention, an open CNC 

system with standard interfaces, modularity, portability, scalability and 

interchangeability. 

4). High performance parts: Focus on the development of 20,000 to 40000r/min 

high-speed electric spindles, multi-axis linkage spindle heads, precision gratings, 

high-precision spindle bearings, 1-2 ball screw guides, turntables with positioning 

accuracy less than 6”, etc. Develop complete sets of equipment for high 

performance parts processing, forming, testing and assembly. 

As such, mold components are not listed as one of the strategic advanced technology 

manufacturing initiatives in the “Made in China 2025” plan. DME’s suppliers are not among 

those that benefit from the Chinese Government's acts, policies or practices identified by USTR, 

as being unreasonable or discriminatory and that burden or restrict U.S. commerce. Milacron and 

its subsidiaries have affiliates operating in China. Neither Milacron nor its affiliates have been 

forced to turn over any intellectual property rights, and innovation control to Milacron’s Chinese 
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suppliers. The above-mentioned longstanding relationships between Milacron, DME and their 

Chinese suppliers have allowed Milacron and DME to rely on dedicated suppliers that have an 

economic incentive to maintain lasting productive relationships and therefore properly maintain 

and protect intellectual property and trade secrets. 

 

****** 

Milacron hereby requests business confidential treatment for certain information clearly 

identified in brackets in the comments above. Milacron certifies that the data include, inter 

alia, business trade secrets, commercial or financial information and certain other 

information, the disclosure of which would endanger trade secrets or profitability, and that 

the information would not customarily be released to the public. Nevertheless, Milacron has 

provided a public version of this submission which can be placed in the public file for 

inspection. 

Please direct any questions concerning this submission to the undersigned. 

Respectfully Submitted 

Daniel Cannistra 

Yun Gao 

Counsel for Milacron 
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     Appendix 

2017 2018 YTD

2016 2017 2017 YTD  2018 YTD  2016 2017 2017 YTD  2018 YTD  2016 2017 2017 YTD  2018 YTD 

China  84669315 33,408,400 39,368,575 18,828,338 26,008,861 27,407,609 30,704,608 14,843,327 18,127,050 1.22 $               1.28 $            1.27 $             1.43 $             82.36% 84.24%

Thailand  84669315 3,958,194 5,709,694 2,138,017 2,864,806 3,021,603 4,570,083 1,889,972 1,748,673 $               1.25 1.31 $            1.13 $             1.64 $             12.26% 8.13%

Korea  84669315 1,028,085 1,089,623 571,178 1,035,596 349,406 435,389 215,178 395,212 $               2.50 2.94 $            2.65 $             2.62 $             1.17% 1.84%

Germany  84669315 1,701,130 627,822 240,538 3,221,770 182,404 49,679 18,319 354,025 $               12.64 9.33 $         13.13 $           9.10 $             0.13% 1.65%

Taiwan  84669315 1,148,992 1,064,105 638,550 649,240 331,058 358,545 247,684 228,777 $               2.97 3.47 $            2.58 $             2.84 $             0.96% 1.06%

India  84669315 24,450 297,198 293,428 231,009 11,833 34,034 33,987 208,840 $               8.73 2.07 $            8.63 $             1.11 $             0.09% 0.97%

Italy  84669315 712,368 661,712 201,333 751,586 44,610 71,580 34,506 104,389 $             9.24 15.97 $            5.83 $             7.20 $             0.19% 0.49%

Japan  84669315 2,164,077 2,413,404 1,287,985 1,094,415 274,462 142,233 37,769 100,961 $               16.97 7.88 $         34.10 $           10.84 $           0.38% 0.47%

Mexico  84669315 228,141 461,449 264,224 276,954 77,293 128,559 57,994 100,045 $               3.59 2.95 $            4.56 $             2.77 $             0.34% 0.46%

Canada  84669315 448,111 1,452,386 761,500 447,416 132,002 211,612 66,485 62,650 $               6.86 3.39 $            11.45 $           7.14 $             0.57% 0.29%

Romania  84669315 350,501 304,374 196,011 145,807 43,161 44,505 27,126 23,072 $               6.84 8.12 $            7.23 $             6.32 $             0.12% 0.11%

Sweden  84669315 75,577 132,673 65,926 168,974 18,366 31,988 1,481 18,051 $               4.15 4.12 $            44.51 $           9.36 $             0.09% 0.08%

Switzerland  84669315 1,643,575 402,501 266,402 499,234 105,806 41,542 27,091 15,121 $             9.69 15.53 $            9.83 $             33.02 $           0.11% 0.07%

Austria  84669315 25,330 7,054 0 53,726 8,363 12 0 13,607 $               587.83 3.03 $       NA 3.95 $             0.00% 0.06%

Argentina  84669315 0 0 0 12,192 0 0 0 8,128 NA NA NA 1.50 $             0.00% 0.04%

Slovak Republic  84669315 23,607 205,409 8,023 50,609 84 7,961 13 3,975 $           25.80 281.04 $         617.15 $        12.73 $           0.02% 0.02%

Finland  84669315 86,340 210,573 0 108,814 15,147 7,674 0 3,678 $               27.44 5.70 $         NA 29.59 $           0.02% 0.02%

Poland  84669315 98,037 28,534 6,403 67,810 11,225 247 68 1,188 $               115.52 8.73 $       94.16 $           57.08 $           0.00% 0.01%

Denmark  84669315 7,483 51,830 2,199 31,249 71 23,441 1 602 105.39 $           2.21 $            2,199.00 $     51.91 $           0.06% 0.00%

Spain  84669315 2,868 2,016,830 10,354 9,598 17 388,253 405 465 168.71 $           5.19 $            25.57 $           20.64 $           1.04% 0.00%

Israel  84669315 60,413 34,536 34,536 18,813 810 11,671 11,671 338 74.58 $             2.96 $            2.96 $             55.66 $           0.03% 0.00%

United Kingdom  84669315 300,899 53,430 9,535 43,573 25,559 9,084 86 300 $             5.88 11.77 $            110.87 $        145.24 $         0.02% 0.00%

Brazil  84669315 11,972 13,249 9,851 11,911 225 139 122 132 53.21 $             95.32 $         80.75 $           90.23 $           0.00% 0.00%

Netherlands  84669315 11,886 0 0 8,933 21 0 0 95 566.00 $           NA NA 94.03 $           0.00% 0.00%

Australia  84669315 9,150 15,258 15,258 14,416 3 62 62 59 3,050.00 $        246.10 $       246.10 $        244.34 $         0.00% 0.00%

Singapore  84669315 5,611 96,200 0 6,102 14 3,602 0 56 400.79 $           26.71 $         NA 108.96 $         0.01% 0.00%

Slovenia  84669315 21,368 13,602 7,057 26,538 17 9 7 27 1,256.94 $        1,511.33 $    1,008.14 $     982.89 $         0.00% 0.00%

Czech Republic  84669315 3,223 0 0 2,896 511 0 0 15 6.31 $               NA NA 193.07 $         0.00% 0.00%

Belgium  84669315 2,832 0 0 0 3 0 0 0 944 NA NA NA 0.00% 0.00%

France  84669315 41,917 99,028 55,731 0 8,397 869 433 0 4.99 $               113.96 $       128.71 $        NA 0.00% 0.00%

Ghana  84669315 8,664 0 0 0 5 0 0 0 1,732.80 $        NA NA NA 0.00% 0.00%

Hong Kong  84669315 223,208 12,600 2,700 0 145,598 1,807 1,357 0 1.53 $               6.97 $            1.99 $             NA 0.00% 0.00%

Hungary  84669315 0 9,800 0 0 0 1,378 0 0 NA 7.11 $            NA NA 0.00% 0.00%

New Zealand  84669315 21,214 12,083 7,676 0 122 60 42 0 173.89 $           201.38 $       182.76 $        NA 0.00% 0.00%

Turkey  84669315 0 2,788 2,788 0 0 11 11 0 NA 253.45 $       253.45 $        NA 0.00% 0.00%

Vietnam  84669315 5,600 0 0 0 1,040 0 0 0 5.38 $               NA NA NA 0.00% 0.00%

Total 47,863,223 56,868,320 25,925,541 37,862,848 32,216,845    37,280,637   17,515,197   21,519,531

8466.93.15

In Actual Dollars

for ALL Countries

U.S. Imports for Consumption

Annual + Year‐To‐Date Data from Jan ‐ Jun

In Actual Units of Quantity

Country  HTS Number  Customs Value ($) Quantity (KG) Unit Price ($/KG)
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: