PRESTO* 

National Presto Industries, Inc. 

Eau Claire, WI 54703-3703 

Via regulations.gov 0% Fax 715-839-2148 

Tel. 715-839-2121 

wwwgopresto.com 

715-839-2122 

715-839-2242 

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

Regulators Classified as HTSUS 8481.10.0090 

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 bagged three-piece Pressure Regulator service part, which 

has a 10-digit HTSUS classification of 8481.10.0090. The internal Part Number is 79-

115. The internal Service Number is 50332. 

Request for Exclusion of Pressure Rezulators 

a) 10 Digit Subheading of the HTSUS Most Applicable to the Regulators 

HTSUS 8481.10.0090 

b) Identification of the Particular Physical Characteristics of the Regulators 

and How They Are Distinguishable From Other Products Coded 8481.10.00 

The 8-digit subheading HTSUS 8481.10.00 covers "pressure reducing valves 

for pipes, boiler shells, tanks, vats or the like." The pressure regulators 

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 regulators at issue are very small in size. The regulators have a diameter 

of 1.37 inches; a height of 1.32 inches; and a weight of 0.185 pounds. The 

material composition of the regulators contains cast zinc, polypropylene and 

stainless steel. 

c) Annual Quantity and Value of Regulators Purchased Last Three Years 

> 2015- Quantity: 8,299 Value: $74,691.00 

> 2016- Quantity: 7,779 Value: $70,011.00 

> 2017- Quantity: 8,742 Value: $78,678.00 

d) Regulators Only Available from China 

The pressure regulators requested for exclusion are only available in China. 

These regulators 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 

Trademark of National Presto Industries, Inc. 

880452D 

October 3, 2018 
manufactured on the same tooling that is used to manufacture the actual 

cookers and canners. The demand for the impacted regulators is such that it 

would not be feasible to tool or print those parts in the United States. 

e) Increasing the Tariff on Pressure Regulators 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 

regulators 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) Pressure Regulators Have No Strategic Importance to the Made in China 

2025 Program 

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

on pressure regulators 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. 

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 regulators 

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 

pressure regulators, which have a ten-digit HTSUS classification of 8481.10.0090. I 

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

knowledge. 

Respectfully Submitted, 

Peter Furrer 

Associate Corporate Counsel