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 Document 

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

8480.71.8045: Injection molds are needed for producing plastic parts for the automotive industry. An 

injection molds is out of steel and has a core and cavity side. The size of the injection mold depends on 

the size of the plastic part (e. g. for a bumper a mold weight may be up to 100,000 lbs). The core and 

cavity are going through different machining operating processes (milling, EDM, drilling etc.). However, 

a significant portion is hand work for polishing and assembly. 

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

8480718045 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Ingels, Cindy - Customs Compliance Supervisor 

REHAU Automotive LLC 

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

Requestor Representative: Cindy Ingels Customs Compliance Supervisor REHAU Automotive LLC 

5. Requestor's relationship to the product: Other 

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. 

N/A 

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

YES 

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

YES 

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: 

2016 Value: 

$ 505,778.00 2017 Quantity: 

2016 Quantity: 

3 

2015 Value: $ 232,908.00 2015 Quantity: 3 

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). 

REHAU is serving the automotive OEM (MBUSI, BMW, Nissan,..) as alst tier supplier w/ large size 

plastic parts. The REHAU plant is located in Cullman AL and ship the parts to the OEM assembly lines 

in SC, AL, TN etc.. The challenges in that business are as follows: 

a) timing 

The project time lines in automotive industry are very tight and dynamic (change management). 

That has an impact on the injection molds and check fixtures as well. As a result, large size mold 

shops w/ experience in automotive and tremendous amount of capacity / flexibility in machining, 

hand work etc. are necessary. Over the last decade, China built up a deep expertise and knowledge 

in that business and is fulfilling these requirements. On the other hand, capacities in the US 

remained stable resp. were reduced (due to missing resources). 

b) pricing 

In automotive business pricing is very tough and customers have very heavy pricing expectations. 

The sourcing of injection molds helps us to earn business and keeping our plant in Cullman AL 

running. 

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