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 particular product of concern:

4.

*

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/

7.

5. Requestor's relationship to the product:

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.

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1

PUBLIC VERSION
8. Is this product, or a comparable product, available from sources in the United States? (If you

9. Is this product, or a comparable product, available from sources in third countries? (If you

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.

2017 Value:

2016 Value:

2015 Value:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

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indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?

PUBLIC VERSION
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).

PUBLIC VERSION
PUBLIC VERSION 

Confidential infonnation of Schindler Elevator Corporation is redacted 

Response of Schindler Elevator Corporation to Section 12 of the Product Exclusion 

Request Form in 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 Teclrnology Transfer, Intellectual Property, and Innovation (USTR-2018-0025) 

Machined Elevator Guide Rails 

October 9, 2018 

Schindler is a leading global manufacturer of elevators, escalators, and moving walk-way 

systems, with its U.S. headquarters in Morristmvn, New Jersey. The Company employs over 

5,000 people in more than 250 locations throughout the United States. For over 135 years, 

Schindler has been an industry leader in the manufacture, installation, and maintenance of 

elevators and escalators, and is an industry leader in modernizing mobility solutions for 

construction projects worldwide. 

Schindler produces elevators for low and mid-rise buildings at its Hanover, Pennsylvania 

facility. The Pennsylvania facility is a state-of-the art LEED Gold-certified 150,000+ sq. ft. 

manufacturing plant. It fabricates critical door, entrance, and cab interior components and 

assembles finished elevator systems used throughout the United States, including the White 

House and 4 World Trade Center in New York City. It also incorporates an industry-leading 

order consolidation facility. Together, these facilities employ over 80 full-time skilled workers 

directly in production operations and over 40 more in related positions. 

A critical part of Schindler's production of elevators in Hanover, Pennsylvania are the 

machined elevator guide rails that it obtains from [ ]. 

[ 

[ 

]. [ 

] . However, based on [ 

]. Moreover, these 

[ 

]. 

1 
PUBLIC VERSION 

Confidential information of Schindler Elevator Corporation is redacted 

Schindler currently estimates that the cost of the tariffs on its imports of machined 

elevator guide rails alone will exceed [ }. [ 

]. Accordingly, if an exemption is not granted, Schindler will have no choice but to 

pay full cost of the tariffs. This will, in turn, impact the company's ability to continue to invest 

in its U.S. manufacturing facilities and hire and train more skilled U.S. workers. As a 

consequence, Schindler is [ 

l 

For all of these reasons, Schindler respectfully requests that USTR grant its request for a 

product exclusion for machined elevator guide rails from China classified under the USHTS 

code and product description set forth herein. 

2 
61593992.1 

DOCUMENT(S) 

INCAPABLE OF PUBLIC. 

SUMMARY