Monday, October 1st, 2018

Ambassador Robert E. Lighthizer

U.S. Trade Representative

Office of the United States Trade

Representative

600 17th Street NW

Washington, DC 20006

Re: USTR-2018-0025 – Procedures to Consider Requests for Exclusion of 

Particular Products from the Determination of Action Pursuant to Section 

301: Subject NSK product consists of non-heat treated, machined, single row ball 

bearing rings made of JIS SUJ2 tube material with an inner diameter ranging 

from 14.85mm to 33.25mm, and outside diameter ranging from 21.0mm to 

47.0mm, and width ranging from 9mm to 12.1mm. (HTS# 8482.99.0500)

Dear Ambassador Lighthizer:

NSK Americas, Inc. and its US subsidiaries are designers, engineers, and manufacturers 

of advanced motion and control technologies that includes anti-friction bearings, steering 

columns, bearing components, and precision products for supply to key US industrial and 

automotive customers and for export outside the US. We employ over 2,400 people in the US in 

design, engineering, manufacturing, technology, financial, and many other capacities. Annually 

we invest in excess of $25m expanding and enhancing our US businesses.

The subject material that we currently source from our Chinese supplier is not available 

domestically. No domestic precision ring machining source has been identified that can cut, 

hone and process NSK approved SUJ2 steel from Japan and China. Precision SUJ2 machining is 

very critical to grinding process and equipment function. These products are also considered a 

critical component of the production of our US produced bearings which impact a safety critical 

application of a vehicle. As such, any premature change in design, material, or process 
(including new source or location) without adequate planning could have severe ramifications to 

the performance of a vehicle. It is also worth noting that these imported rings are used to support 

US final processing and assembly of various bearings located in our Clarinda, Iowa plant (320 

plant related employees).

Furthermore, the reason NSK decided to source from China is due to cost 

competitiveness. Our US based plants (Clarinda, IA and Franklin, IN) are mostly automotive 

based production plants in order to strategically align with our customers’ needs. This required

NSK's automotive business to find an overseas plant to help support the lower volumes and 

unique production requirements at a reasonable cost for our myriad customers in this 

complicated business segment. As such, NSK continues to compete against nonlocal 

competitors from low labor regions and therefore our sourcing of low risk items is our best effort 

to keep manufacturing in North America where labor costs are regionally competitive but not 

globally. However, we did not simply start buying “cheap” bearing components from a Chinese 

company. We transferred this business to a supplier in China so that we could be assured of 

receiving bearing components manufactured to NSK’s uncompromising quality and safety 

standards related to the US produced bearings in question. 

Additionally, the imposition of these Section 301 duties had a direct, immediate, and 

severe impact to our company, which we have already absorbed from a cost standpoint. This has 

affected both sales and profitability (profit margin) across our internal business segments. We 

have had to also pass on a portion of the tariff cost to our customers (who use our bearings in 

their US manufacturing process) which will eventually hurt the ultimate end user - the individual 

consumer.

We are also not aware of any impact the production of the subject bearing rings have had

as it relates to the "Made in China 2025" initiative or any other Chinese industrial based 

program. This is due to the fact that bearing design and development, along with respective sub-
components, have been traditionally considered low-tech given that the bearing components in 

question go through merely a tube cutting and machining process which can essentially be 

performed anywhere.

Please note that NSK Corporation, to our knowledge, has not been harmed by any China 

policies and/or practices as it relates to Intellectual Property Rights, including the transfer of 

technology. Moreover, anti-dumping on majority of bearings and its respective sub-components 

was removed as recently as mid-2014 when USITC ruled anti-friction bearings were not being 

sold below US market value, further justifying the exclusion of any type of additional duties.

Lastly, NSK is unaware of any potential issues that would affect the ability of US CBP to 

administer subject exclusion. CBP should be able to easily identify the products based on 

HTSUS code, MID, and country of origin.

As such, we respectfully request exclusion from Section 301 for our product classified 

under HTS# 8482.99.0500, which is produced and sourced from China.

Sincerely,

Steven A. Beckman

NSK Americas, Inc. 

Chief Executive Officer 

beckmas@nsk-corp.com

(734) 913-7500