Office of the United States Trade Representative 600 1 ?'h Street NW Washington, DC 20508 

Re: Request for an Exclusion from Proposed Determination of Action of 25 percent ad valorem duty on products of China Pursuant to Section 301 of the Trade Act of 1974. Dear Ambassador Lighthizer: 

VITA-MIX Manufacturing Corporation hereby submits its request for exclusion from 25 percent ad 

valorem tariff imposed by the President in Proclamation 83 FR 28710 of June 20,2018 as amended. 

I. Product Overview: Switches for controlling electrical current in Household and Commercial Blending 

Equipment • Product Name/HSUS Description: Electrical apparatus for switching or protecting electrical 

circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes), for a voltage not exceeding 1,000 V; connectors for optical; fibers, optical fiber bundles or cables: Other switches: Other: Other 

• Product Classification: HTS US# 8536.50.9065 • Marketing Information: Custom Manufactured switches specific to Vitamix equipment not 

currently manufactured elsewhere. 

II. Company's Relevant Business Activities: 

• VITA-MIX Manufacturing Corporation is an American company located in Strongsville, Ohio and 

Olmsted Township, Ohio. VITA-MIX Manufacturing Corporation is a manufacturer of the world's 

best performing and most reliable blending solutions. 

• VITA-MIX Manufacturing Corporation provides jobs for 700 individuals, in a local community 

where the company is part of the fabric of its economic support. VITA-MIX Manufacturing Corporation has a strong history of compliance with U.S. regulations, and intends to comply with 

updated tariffs. However, making the necessary changes in relationship and normal operations 

will take time; an international supply chain does not adjust speedily. Thus, it is necessary to 

request an exclusion to address these matters. 

8615 Usher Road Cleveland, Ohio 44138-2103 USA Tel 440.235.4840 vita mix.com Page 1 of 3 
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>- VITA-MIX Manufacturing Corporation sources switches for controlling electrical current in 

Household and Commercial Blending Equipment from key suppliers that significantly 

contribute to its business inventory. Forming relationships with these suppliers was a 

multi-year process that required immense resource investment, including personnel 

time. Without an exclusion, VITA-MIX Manufacturing Corporation relationships with these suppliers that are so important to the continued operational success of the 

company will be negatively impacted. 

>, Further, it will be difficult for VITA-MIX Manufacturing Corporation to form new supplier 

relationships in time to avoid economic loss, especially since all U.S. manufacturers will be facing similar constraints. Currently U.S. suppliers are not functioning at sufficient capacity, or do not possess the capacity at all. Specifically for subject product, the sole 

U.S. manufacturer ceased operations in 2016 and liquidated their assets. Prior to that, 

qualification for the current source took 18 months. 

b. VITA-MIX Manufacturing Corporation Would Suffer Severe Economic Harm 

>, Significant business loss would ensue if VITA-MIX Manufacturing Corporation is not given 

an exclusion from section 301 duties. Breaking from our current supplier contracts would 

be very expensive. Supporting U.S. manufacturers in development of industry will be 

costly and resource intensive . Further, the consequences of this loss would result in 

damages to employees, consumers and other U.S. businesses. 

>, Employees would suffer in the form of potential layoffs. Consumers would suffer in the 

form of increased prices on every single item they purchase from VITA-MIX. Since VITAMIX Manufacturing Corporation takes pride in sourcing as much U.S. content as practical, 

other U.S. businesses, primarily suppliers within the state of Ohio, would suffer since 

VITA-MIX Manufacturing Corporation would have to reduce the amount of business 

transactions with them due to the increased cost. 

c. The Class of Merchandise Being Imported is Not One That Is Currently the Source of 

Intellectual Property Rights Violations 

>, VITA-MIX Manufacturing Corporation should be given an exclusion since the item being 

imported is not part of the items that are the source of intellectual property rights 

violation by China. VITA-MIX Manufacturing Corporation appreciates the government's 

efforts to address IPR violations by China, and believes an exclusion is warranted when the item is not part of the source of IPR violation. 

>- Switches for controlling electrical current in Household and Commercial Blending 

Equipment are not related to the initiatives in "Made In China 2025", which focuses on 

high-technology items. 

8615 Usher Road Cleveland, Ohio 44138-2103 USA Tel 440.235.4840 vita mix.com Page 2 of 3 
Loree W. Connors President 

VITA-MIX Manufacturing Corporation 

(440)782-2401 lconnors@vitamix.com 

8615 Usher Road Cleveland, Ohio 44138-2103 USA Tel 440.235.4840 vita mix.com Page 3 of 3