PUBLIC VERSION 

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. 

!Public Version of BCI I 

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

Hot Runners are customized internal components of plastic injection molding machines. The systems 

consist of individually designed heated channels that maintain proper processing temperature for molding 

material. Molten molding material exits through the nozzle of the hot runner. Hot Runners are designed 

in a variety of configurations to produce various component parts of automobiles. 

HTS US description: 8477 Machinery for working rubber of plastics or for the manufacture of products 

from these materials. 8477.90 Parts. 8477.90.8501 of injection-molding machines. 

3. IO-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/ 

8477908501 

4. Requestor Information 

Requestor Name (Last, First): !Jessica McCormack !=========================================~ Organization Name: L.:IB:....;a;;.;.r.:.; n..:.. es~G-=-ro..:..u.;;.Jp---In_c_. _ __________________ __. 

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

Requestor Representative: !Nicolas Guzman - Drinker, Biddle & Reath LLP 

5. Requestor's relationship to the product: L.:!I.:....m...!.p __ o_rt_e_r _ _ ______ ___ ___ ____ __.. 

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

!vEs 

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 l CONTINUED BELOW 
PUBLIC VERSION 

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

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. 

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 notice (note: text entered below can extend 

beyond the apparent size of this box). 

Please see attached supporting letter. 

We request confidential treatment for the information in brackets (identified by"(]") in this 

submission, which contains Synventive's confidential business information. Public release of the 

information would endanger Synventive's profitability and competitive position because it would 

reveal confidential supply chain information as well as information on business operations not 

otherwise available to the public and not customarily released to the public. Additionally, the 

confidential business information is exempt from public disclosure under the Freedom of Information 

Act, 5 U.S.C. §552(b)(4). A public version of these comments is also being filed with all confidential 

information redacted. 

VERSION 1 END 2 
11:ynventive® 

molding solutions '-A buliness ot 8..ARNES GROUP INC 

VIA ELECTRONIC FILING 

SYNVENTIVE MOLDING SOLUTIONS 

10 CENTENNIAL DRIVE 

P EABODY, MA 01960 

UNITED STATES OF AMERICA 

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

600 17t1, St. NW 

Washington, DC 20508 

TEL! +1.978,7S0.8065 

FAX: +1.978,646.3600 

EMAIL: INFO@SYNVENTIVE . COM 

Wea: WWW.SYNVENTIVE.COM 

PUBLIC VERSION 

Docket No.: USTR-2018-0025 

Subject: Synventive Molding Solutions, Inc. Request for Exclusion from Section 301 

Tariffs of Certain Hot Runner Systems 

Dear Ambassador Lighthizer: 

Synventive Molding Solutions, Inc. ("Synventive"), headquartered in Peabody, Massachusetts and a 

business of Barnes Group Inc. ("Barnes Group"), respectfully requests an exclusion from the Section 

301 tariffs for Synventive manufactured hot runner systems (classified in HTSUS 8477.90.8501). 1 

A complete and detailed description of the product is provided in the exclusion request form. 

I. Background 

Synventive is a global leader in made-to-order hot runner systems and valve gate control technologies 

for the plastic injection molding industry and a pa11 of Barnes Group's Molding Solutions business 

unit. Barnes Group (NYSE: B), headquartered in Bristol, Connecticut, is a global provider of highly 

engineered products, differentiated industrial technologies, and innovative solutions, serving a wide 

range of end markets and customers. 

Synventive engages in the design and manufacture of hot runner systems and components for injection molding applications in the United States and internationally. From initial design and engineering to the finished system, Synventive combines premium materials, precise component production 

and thorough testing to produce high quality, dependable and economical tool-based solutions for our 

customers. 

Synventive custom designs and manufactures each Hot Runner System in Peabody, Massachusetts or 

at its wholly owned subsidiary companies in Bensheim, German and Suzhou China. [ 

] A 

25% tariff on Synventive's Hot Runner systems may impact the price and competitiveness of U.S. 

automakers as Synventive will be forced to pass on this cost to its customers. 

1 See Customs New York Ruling Letter NOl 9120 dated November 27, 2007. 

1 / 4 
l:ynventive® 

molding solutions • A~ of 9AAN£S ~OUP lNC 

SVNVENTIVE MOLDING SOLUTIONS 

10 CENTENNIAL DRIVE 

PEABODY, MA 01960 

UNITED STATES OF AMERICA 

TEL: +t.978.750.8065 

FAX: +1.978,646,3600 

EMAIL: INFO@SVNVENTIVE.COM 

Wee: WWW.SVNVENTIVE . COM 

Operating in a global market, Synventive has a wholly owned subsidiary in China, Synventive Molding Solutions (Suzhou) Co., Ltd. which in turn operates our own factory. In our China facility, we 

directly manufacture the imported hot runner systems with our proprietary technology and valuable 

trade secrets, and also perform rigorous quality control inspections and testing. These imported products improve the speed, price, and quantity of products we are able to offer in the U.S. and enrich our 

overall product offering. Further, by keeping hot runner system manufacturing in-house, we best 

ensure the protection of our intellectual property. 

II. Product Information 

Hot runner systems are molten plastic conveying units used within an injection mold machine to 

produce plastic parts. The systems consist of individually designed heated channels that maintain 

proper processing temperature for molding material. Molten molding material exits through the nozzle of the hot runner at pre-determined locations based on customer specifications to supply the molten plastic used in the manufacture of precisely designed automotive parts. For your reference we 

have included images of various configurations as Exhibit 1 to this addendum. 

The following is suggested language for the administration of the requested exclusion: 

"Injection mold machine molten plastic conveying units, with heated channels, incorporating nozzles." 

III. Basis for Exclusion 

a. Synventive is unable to source its Hot Runner Systems from third-party fabricators in 

the U.S. or elsewhere. 

All Synventive Hot Runner Systems are highly complex products designed and manufactured 

by Synventive in our Peabody, Massachusetts, Gennan and Chinese manufacturing facilities. 

Each Hot Runner System is specialized and custom designed for our customers based on 

specific customer applications. No t\'VO Hot Runner Systems are the same. 

There are no Hot Runner manufacturer's that are not direct competitors of Synventive, therefore, if we sourced our Hot Runners elsewhere, the only viable source would be our competition. Putting Synventive intellectual property into the hands of our competitors wou ld undermine our competitive position as a leader in innovation for our industry. This would require us to disclose to our competition our proprietary intellectual property, including our 

valuable trade secrets, in which we have invested significant resources, and assist them in 

developing a capability that could be used to unfairly compete with us. 

Synventive' s competitive position is due, in large part, because of our in-house manufacturing 

capability. Our in-house manufacturing allows us full control over quality and intellectual 

property. This structure also allows us to devote significant resources to producing more 

technologically sophisticated, higher margin hot runner systems in the U.S., because those 

special products are typically lower volumes with much shorter lead times for U.S. customers. 

Our Suzhou facility, which we fonned in 2004, increases U.S. commerce by complementing 

our Peabody, Massachusetts facility and allows us to offer a full-range of products to our U.S. 

and global customers. Our manufacturing site in Suzhou, China has no government or state2 / 4 
l:Y!,11~9

~!i!Y.~· ,. A~, of BARNES GROUP lNC 

SYNVENTIVE MOLDING SOLUTIONS 

10 CENTENNIAL DAIVE 

PEABODY, MR 01960 

UNITED STATES OF AMERICA 

TEL: +1.978,750,8065 

FAX: +1.978.646.3600 

EMAIL: INFO@SYNVENTIVE. COM 

WEB: WWW,SYNVENTIVE,COM 

owned enterprise ("SOE") investment. As our own facility, there have not been any issues 

associated with the forced transfer of technology to which the additional 25% duties seek to 

remedy. 

b. Synventive is unable to move Chinese production to the U.S. without undermining its 

financial position 

However, Synventive cannot produce the entire high-volume of hot runner systems more 

efficiently in the U.S. due to the increased labor costs, higher raw materials costs and 

associated overhead expenses in the U.S. Further, it does not make economic sense to 

convert Synventive's U.S. resources devoted to more customized products, R&D, and 

other product innovation activities to the manufacture of standard hot runner systems 

currently manufactured in Suzhou. Doing so would undermine the speed with which we 

are able to introduce new products and product improvements, force us to put on hold 

valuable development products and R&D activities, and adversely impact our competitive 

position in the marketplace. Our China facility is able to produce high quality standard 

hot runner systems in the most efficient cost-effective manner. Nor can we increase our 

capacity fast enough to meet the demand of our customers. Any conversion of our Chinese production to the U.S. or elsewhere would require considerable time and expense, 

including the major expansion of our existing facility or construction and development of 

new facilities at a significant cost. 

c. Conclusion 

These products are not economically and commercially available outside of China; they are not hightech products that are benefiting from the "made in China 2025" program; and the tariffs would not 

advance the Administration's stated goal of reducing China's unfair access to intellectual property or 

prohibiting forced technology transfers. Rather, the imposition of additional 25% duties on these 

products would significantly undermine Synventive's competitive advantage in both the U.S. and 

global market. 

We request confidential treatment for the information in brackets (identified by"[]") in this submission, which contains Synventive's confidential business information. Public release of the information would endanger Synventive's profitability and competitive position because it would reveal 

confidential supply chain information as well as information on business operations not otherwise 

available to the public and not customarily released to the public. Additionally, the confidential 

business information is exempt from public disclosure under the Freedom of Information Act, 5 

U.S.C. §552(b)(4). A public version of these comments is also being filed with all confidential information redacted. 

3 / 4 
l:Y!,1~~9

~!i!Yo~· - A lw$ineu of BARNES GROUP INC 

SYNVENTIVE MOLDING SOLUTIONS 

10 CENTENNIAL DRIVE 

PEABODY, MA 01960 

UNITED STATES OF AMERICA 

TEL: +1,978, 750,8065 

FAX; +1,?70,646,3600 

EMAIL: INFO@SVNVENTIVE . COM 

WEB: WWW, SYNVENTIVE,COM 

Synventive appreciates the consideration of its comments and is available for additiona.l input or 

information if requested. lf you have any questions concerning this request, please contact: John 

Sundt via phone at 860.409.4684 or via email at jsundt@BGlnc.com or Steven Gayfer via phone at 

978.646.3671 or via email at SGayfer@Synventive.com. 

Sincerely, 

Scott Mayo 

Sr. VP, Barnes Group Inc. 

President, Barnes Industrial 

4 I 4 
Exhibit 1 

)