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:
October 9, 2018

Ambassador Lighthizer

U.S. Trade Representative

600 17th St., N.W.

Washington, DC 20508

PUBLIC VERSION

BUSINESS PROPRIETARY INFORMATION FOR WHICH PROPRIETARY 

TREATMENT IS REQUESTED HAS BEEN REMOVED BETWEEN BRACKETS ON 

PAGE 5

Re: 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

USTR-2018-0025-001

Dear Ambassador Lighthizer: 

2Q EHKDOI RI WKH 7RUPDFK ,QF 37RUPDFK ́ , KHUHE\ VXEPLW D UHTXHVW IRU D SURGXFW

specific exclusion of HTSUS 8428.90.0220 for Industrial Robot Prototype. A formal description 

of the Industrial Robot Prototype is detailed below in Section III. 

Tormach hereby requests business confidential treatment for business proprietary 

information between single brackets in this submission. The disclosure of business proprietary 

information would endanger trade secrets or profitability, and this information would not 

customarily be released to the public. 

I. Executive Summary

Tormach submits that the 25-SHUFHQW DGGLWLRQDO GXWLHV RQ 7RUPDFK¶V ,QGXVWULDO 5RERW

Prototype will cause disproportionate economic harm to U.S. interests, including our company, 

our U.S. manufacturing facilities, and small and medium sized business that rely on our products