wwwgopresto.com 

Tel. 715-839-2121 

Via regulations.gov Fax 715-839-2148 

715-839-2122 

715-839-2242 

Re: Request for Exclusion from National Presto Industries, Inc. for Vent Pipes 

Classified as HTSUS 8481.40.0000 

National Presto Industries, Inc. ("NPI") is writing to express its deep concern with the 

Office of the United States Trade Representative's (USTR) proposal to use a 25% tariff 

increase to address China's unfair trade practices and its trade investment relationship 

with the United States. As explained in more detail below, NPI requests an exclusion 

from the tariff increase for its vent pipe service part, which has a 10-digit HTSUS 

classification of 8481.40.0000. The internal Part Number is 29-025. The internal Service 

Number is 29025. 

Request for Exclusion of Service Parts 

a) 10 Digit Subheading of the HTSUS Most Applicable to the Service Part 

HTSUS 8481.40.0000 

b) Identification of the Particular Physical Characteristics of the Service Part 

and How They Are Distinguishable From Other Products Coded 8481.10.00 

The 8-digit subheading HTSUS 8481.40.00 covers "safety or relief valves for 

pipes, boiler shells, tanks, vats or the like." The service parts requested for 

exclusion by NPI are therefore distinguishable from other products within the 

covered 8-digit subheading 8481.10.00 in that they are used as service parts 

for small consumer household appliances, specifically pressure cookers and 

canners. Pipes, boiler shells, tanks and vats are not consumer household 

products. 

The service parts at issue are very small in size. They have a diameter of 0.31 

inches; a height of 1.04 inches; and a weight of less than 0.1 pounds. The 

material composition is stainless steel. 

c) Annual Quantity and Value of Service Parts Purchased Last Three Years 

2015- Quantity: 970 Value: $4,365.00 

2016- Quantity: 0 Value: $ 0.00 

2017- Quantity: 950 Value: $4,275.00 

d) These Service Parts Are Only Available from China 

The service parts requested for exclusion are only available in China. These 

parts are critical for the safe operation of the cookers and canners. The best 

way to assure that the parts meet specification is to have them manufactured 

on the same tooling that is used to manufacture the actual cookers and 

Trademark of National Presto Industries, Inc. 

680452D 

October 3, 2018 Jo PRESTO* 

National Presto Industries, Inc. 

Eau Claire, WI 54703-3703 
canners. The demand for the impacted parts is such that it would not be 

feasible to tool or print those parts in the United States. 

e) Increasing the Tariff on These Service Parts Will Have No Impact on the 

Trade Deficit 

An increased tariff on NPI's service parts and small consumer appliances will 

have no impact on the trade deficit, but would increase the price of the part to 

the consumer. If the tariff goes through, NPI will continue to import the 

service parts into the U.S. as long as there is a consumer demand to pay the 

higher price. If demand from consumers after the price increase drops to the 

point that offering the part is no longer feasible, the part will be discontinued. 

Given the dollars involved, discontinuance of this service part will have no 

impact on the trade deficit. 

f) These Service Parts Have No Strategic Importance to the Made in China 

2025 Program 

Stated simply, there is absolutely no correlation between the proposed tariffs 

on these service parts for pressure cookers and canners and the Made in China 

2025 Program. Made in China 2025 is Beijing's plan to transform China 

into a hi-tech powerhouse that dominates advanced industries like 

robotics, advanced information technology, aviation, and new energy 

vehicles. 

Service parts for pressure cookers and canners have no strategic 

importance to that Made in China 2025 Program. The Chinese are not 

interested in any intellectual property or technological innovations relating to 

these service parts because the technology is dated. These parts have been 

features in pressure cookers since NPI introduced the first pressure cooker 

using a rotating lid and gasket during the World's Fair in 1939. There are 

simply no innovations or technological advances to be made relating to these 

service parts. 

For the reasons stated above, NPI requests an exclusion from the tariff increase for its 

vent pipe service parts, which have a ten-digit HTSUS classification of 8481.40.0000. I 

certify that the infoimation provided herein is complete and correct to the best of my 

knowledge. 

Respectfully Submitted, 

Peter Furrer 

Associate Corporate Counsel