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
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.

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?

VERSION 2 CONTINUED BELOW 2
12. Please provide information in support your request, taking account of the

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).

VERSION 2 CONTINUED BELOW 3
1

Robert Bosch Tool Corporation – Addendum to the Exclusion Request

Response to Section 12:

Robert Bosch Tool Corporation (“the Company or Bosch”) imports combination laser kits fully 

assembled and available for use by end customers at the time of import. The product concepts are 

developed in the US and then shared with the engineering team in Hong Kong for production at Robert 

Bosch Tool Corporation’s manufacturing facility, Bosch Laser Equipment (Dongguan) Limited in 

Dongguan, China. 

Consistent with USTR's Section 301 notice, Bosch requests confidential treatment for the information 

designated as business confidential in this submission. Such information consists of information that 

would not customarily be released to the public, including business or trade secrets regarding production 

costs and processes, data on sales, product characteristics, customers, destinations, and other product, 

sales, and cost-related business secrets. Business confidential information has been indicated herein by 

enclosing it in single brackets (“[ ]”). A public version of these comments is also being filed with all 

confidential information removed.

A. Example of one of Robert Bosch Tool Corporation’s Combination Laser Kit

B. Made in China 2025

To the best of our knowledge, the Company’s combination laser kits do not benefit from the 

Chinese industrial policies and initiatives such as “Made in China 2025.” It is our understanding 

that the Made in China 2025 policy is focused on investment in robotics and other cutting edge 

technologies that take Chinese manufacturing capabilities forward and increase speed and 

efficiency against global competitors. Specifically, this program identifies, for example, priority 

sectors such as: information technology, robotics, aerospace and aviation, maritime engineering, 

advanced rail equipment, new energy vehicles, bio-medicine, high-performance medical devices 

and heavy agriculture machinery. This program is not directed at items using low or medium

levels of technology. 

The item(s) at issue are not subject to Chinese governmental oversight, control or restriction. The 

Bosch laser leveling technology is not strategically important to any Chinese industrial programs 

including Made in China 2025 and contains a medium level of technology.
2

Finally, Bosch has not been required to provide any of its intellectual property or technology to 

China as part of the manufacturing of its finished good and none of the production processes 

utilize articles of interest in the Made in China 2025 program.

The engineering and design associated with the combination laser kit is only used by Bosch’s 

related entity in Dongguan, China. The combination laser kit is not subject to any industrial 

policy favoring local production at the expense of foreign made items. 

C. Background on Bosch United States Companies

The Bosch group of companies provide services and products in the areas of automotive and 

industrial technology, consumer goods and building technology. Having established a U.S. 

presence in 1906, the Bosch group of companies today employs more than 18,000 associates at 

facilities across the U.S. For example, Robert Bosch LLC has three dedicated Research and

Development Centers (Pittsburgh, Pennsylvania; Sunnyvale, California; and Cambridge, 

Massachusetts) and manufacturing and other facilities in Michigan, Illinois, Indiana and South 

Carolina. Other Bosch companies have facilities in Arkansas, California, Florida, Georgia, 

Kentucky, Minnesota, New York, North Carolina and Pennsylvania.

The U.S. has been a competitive location for the Bosch group of companies for many years. 

Bosch continues to actively grow in the U.S. and is planning future investments amounting to 

approximately $152 million to expand the plant in Anderson, South Carolina. This expansion will 

allow for an increase in production of automotive electronic components. Additionally, Bosch is 

working to develop a new Bosch Center for Artificial Intelligence research lab in Pittsburgh, 

Pennsylvania.

Bosch is also committed to supporting and empowering American workers. Associates at the 

various Bosch companies in the U.S. have access to a broad variety of training programs and 

skill-building, including apprenticeship programs at manufacturing facilities. These opportunities 

enable current employees and students to receive hands-on training and gain valuable experience 

while working at a Bosch site.

In addition, one of Bosch’s top priorities is to support the local communities where various Bosch 

companies operate through grants and volunteering efforts. Since its first grant in 2012, the Bosch 

Community Fund (“BCF”) has awarded more than $20 million to organizations and educational 

institutions across the U.S. In 2017 alone, the BCF provided 183 grants to various organizations 

in 40 communities across the country. Bosch associates in the U.S. also volunteer tens of 

thousands of hours to benefit community organizations, including FIRST® Robotics and various 

other STEM educational programs.

D. Financial Hardship 

[ ]

E. Customs Enforceability

Bosch requests exclusion for its combination laser kit classified under USHTS 9031.49.9000

HTS. While imports from China under this subheading may continue to be subject to the 

additional duties under §301, we propose that the abovementioned product be excluded through 
3

the transmission of the USTR docket exclusion request number (eg. USTR-2018-0025-xxx), or 

through transmission of any unique exclusion approval number issued by the USTR. 

Upon approval of the exclusion, this information will be transmitted to all of our licensed and 

authorized customs brokers and Bosch’s internal systems will be updated to reflect the approved 

exclusion. Bosch, and its customs brokers, will have the ability to transmit the information 

through ACE via the data field for applicable ruling numbers. Bosch will also maintain 

information relevant to any granted exclusion within our internal parts database.

F. Conclusion

As addressed above, these products fall outside of high technology products that are the focus of 

the Made in China 2025 program. [ ]

To the best of our knowledge, the information included herein is complete and accurate.