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:
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October 8, 2018 

VIA REGULATIONS.GOV PUBLIC 

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

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Re: Request for Exclusion of Leaded Ceramic Capacitator Part 954047-43502 (FK16X7R1H474KNELB) 

from the Determination of Action Pursuant to Section 301 Tariffs

Dear Ambassador Lighthizer: 

Aisin Electronics Inc. (AEI) respectfully submits this request for exclusion of Leaded Ceramic Capacitor 

from the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

World Corp. of America headquarters are in Northville Michigan. In addition, our research and development 

capabilities can be found throughout the United States. 

1

 19 U.S.C. § 2411. 
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AEI manufactures electronic systems used to control products such as sunroofs, power sliding door 

systems, etc. (electronic parts). These parts are transferred to our customers, automotive OEMs in the United 

States to be assembled into vehicles. 

Our approach has always been to follow a global strategy and establish our family of companies in the 

U.S.to support the U.S. domestic and U.S. import manufacturer base. 

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid to long range, our 

strategy in the United States is to squarely focus on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customers. For AEI this is an investment for the future we gladly make. 

The product we cite in this 301 exclusion request is purchased from China because it meets our 

engineering requirements. We are unaware of any other source, in the United States or abroad, which can 

supply the same product to our specific needs and those of our OEM customers in the United States. 

We are constantly striving toward product improvement that will benefit consumers and its emphasis on 

environmental sustainability, community involvement and employee life balance, Aisin consistently lives up to 

its motto: “For a Better Tomorrow.” 

This exclusion request addresses leaded ceramic capacitators classified under HTSUS subheading 

8532.24.0060 subject to the 25% additional Section 301 tariff. 
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In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2 AEI provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China 

The leaded ceramic capacitator is a key component of our electronic assemblies. The product as required 

by our company is only available from China. Our U.S. customer specifications are exact and rigorous. AEI is 

not aware of any immediately available U.S. or third-country sources for the same or comparable products. 

Furthermore, any supplier-change would require at least one year of testing and customers’ requalification and 

approval. Nor are we aware of any emerging capacity in the United States which could immediately provide 

AEI and our US customers with a validated product. For an automobile, the quality and consistency of materials 

and components are of the utmost importance because they can impact the vehicles quality, safety, and 

performance. 

In short, this product from China has met the final approval of our automotive partners and customers in 

the United States. The process to validate a new supplier will require extensive testing to validate the product, 

both for our purposes as well as our OEM customers. This testing, depending on the customer requirements and 

usually could take 12 to 18 months to complete. More importantly perhaps, as we noted above, there is 

significant risk involved with the quality and delivery aspects of this revalidation in terms of production 

schedules 

This particular product, as specifically configured to our production needs, is not available outside of 

China. The company’s U.S. operations would suffer economically if we were forced to locate an alternative 

supplier as this would engender significant delay costs, requalification assessment costs, and potential loss of 

2 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, 83 Fed. Reg. 32,181 (USTR July 11, 2018). 
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our OEM customer. In fact, any supplier change would require one year (or possibly more) to meet our 

customer approval demands. 

2. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requester or other US interests 

The leaded ceramic capacitator that are included on the USTR’s product list is a key component of our 

automotive parts manufacturing and are imported to support domestic manufacturing operations and American 

jobs in the United States. The imposition of a 25% tariff on these automotive parts could cause severe 

economic harm to U.S. interests, including our employees, our customers, and consumers, who eventually will 

be paying higher prices for new vehicles. Specifically, any future business opportunities involving these 

products could be directly impacted by the price increase caused by the additional tariff. Our concern here is 

that the 25% tariff will impact the company’s production costs, reducing profit margins and therefore 

minimizing any future R&D investments, in the long-run negatively impacting production strategy. This will, in 

turn, adversely affect a broader spectrum of U.S. interests, including U.S. investments, and jobs. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or other 

Chinese industrial programs 

The imposition of a 25% ad valorem duty on leaded ceramic capacitators from China will not impact the 

Chinese intellectual property violations these seek to eliminate. Section 301 tariffs are aimed at specifically 

targeted products that have benefitted from the China’s acts, policies, and practices detailed in the USTR’s 

Section 301 Report. Made in China 2025 aims to promote their indigenous research and development 

capabilities. The ceramic capacitators are not a new technology. 
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We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted, 

Larissa V. Koursova 

Assistant General Manager, Purchasing 

Aisin World Corp. of America 

Phone +1 734 582 7654 

Mobile +1 248 756 9958 

lkoursova@aisinworld.com