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.

VERSION 2 CONTINUED BELOW 2

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
Polaris-Addendum for Wheel Hub Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

OPCILARIS~ 

I. Executive Summary 

Polaris Industries Inc. ("Polaris") is a stalwart U.S. manufacturing company that represents the 

U.S. paradigm of a strong American brand competing and winning in the global marketplace. 

Our vision is to fuel the passion of riders, workers and outdoor enthusiasts around the world by 

delivering innovative, high-quality vehicles, products, services, and experiences that enrich their 

lives. 

Our company has become synonymous with adventure and passion, in both work and play. For 

nearly 65 years, we have been making high-quality, breakthrough products-whether launching 

the snowmobile industry, reinventing ATV categories year after year, developing the first 

purpose-built ultra-light military vehicles, or introducing a radical 3-wheel mote-roadster. 

Polaris stands firmly behind the Administration's goal of freer and fairer global trade based on a 

rules-based system by which all countries must abide. We greatly appreciate the commitment of 

the President and his Administration to strengthening U.S. manufacturing and supporting 

American manufacturing jobs. We also support the Administration's goal of holding countries 

and competitors accountable to playing by the rules. Placing all industry on a level playing field 

allows capitalism to flourish, and we are confident Polaris will succeed in that environment. 

Polaris, however, respectfully requests that USTR mitigate the adverse impacts of the Section 

301 tariffs on Polaris' U.S. manufacturing operations. Mitigating those impacts will avoid the 

unintended consequence of providing foreign competitors, which manufacture outside the United 

States, a competitive advantage over Polaris and its U.S.-produced vehicles. 

USTR can minimize the potential harm to U.S. manufacturers like Polaris by (1) granting the 

product-specific exclusions requested in this and other submissions; and (2) expanding the 

exclusion criteria available under the Section 301 process. [ 

1 
Polaris - Addendum for Wheel Huh Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

] 

II. Specific Exclusion Request for Wheel Hub Bearings 

Polaris' imported wheel hub ball bearings should be excluded from Section 301 tariffs as Polaris 

is in the process of re-sourcing these bearings from outside of China. [ 

] Since Polaris is 

actively shifaing sourcing away from China- which is an Administration trade policy objective -

Polaris requests that its imported wheel hub bearings be excluded from the Section 301 tariffs 

during the re-sourcing process. 

A. Additional Information about Product Description (Question 2) 

Wheel hub bearings are sealed ball bearings and are used on Polaris off-road vehicles. Polaris' 

wheel hub bearings have a steel cage with inner and outer rings, metal balls, rubber seals, and 

specific grease/lube. They are crucial to the proper functioning of the hub, tire, and wheel 

assemblies. Wheel hub bearings need to support the weight/load of Polaris vehicles, while 

reducing or eliminating friction. 

For the purposes they serve, wheel hub bearings are often made of high quality steel. All the 

components within a wheel hub bearing (balls, grease/lube, seal) help to keep the bearing in 

excellent shape. If any of the components fail, the bearing is damaged and requires 

replacement. Leaving a damaged wheel bearing in an assembly for too long can result in 

steering issues ( e.g. loose/non-responsive steering), grinding noises, and uneven tire wear. 

Polaris is specifically requesting exclusion for wheel hub angular contact ball bearings, not 

flanged which are specifically classified as USHTS 8482.10.5024. 

For informational purposes, the following is the picture of a wheel hub bearings: 

2 
Polaris - Addendum for Wheel Huh Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

B. Additional Information about Question 8 (Comparable U.S. Merchandise) 

and Question 9 (Third Country Merchandise) 

Wheel hub bearing manufacturers exist in both the U.S. and in third countries. As shown below, 

Polaris is actively attempting to re-source the wheel hub bearings from suppliers outside of 

China. [ 

] Given that Polaris is moving production outside of 

China, Polaris respectfully requests that USTR grant this exclusion to provide the time necessary 

to allow Polaris to re-source the parts without having duties imposed. 

[ 

] The following is the timeline for this re-sourcing project: 

Timeline: 

[ ]- Onsite visits & supplier qualification 

[ ]- Third party testing of bearings 

[ ] - Final supplier selection and awards 

[ ] - Define material, equipment, and tooling required 

[ ] - Procure material, capital equipment, and install 

[ ] - Test and start up equipment 

[ ] - Assemble first off tool parts 

[ ] - DVP&R (design verification, plan, and report) and validation 

Validation Timing by Product: 

Task Time Notes 

(weeks) 

Teardown Review [ ] 

Build test vehicle [ ] 

Prep/ship test vehicle [ ] 

Field test ( I Ok general [ ] $[ ] 

on-road miles) cost of vehicle) 

Return shipping of [ ] 

vehicle 

3 
Polaris -Addendum for Wheel Huh Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

Teardown/Inspect [ ] 

vehicle 

Total [ ] 2 vehicles can be tested at a time; add'I sets of 2 vehicles would 

need to be tested in series 

[ ] - Production ramp up, run at rate audits, launch production demand 

Total time spent to onboard new supplier and re-source parts= about [ J 

Because Polaris is doing what USTR is requesting, namely moving production of the wheel hub 

bearings outside of China, Polaris respectfully requests that USTR provide Polaris with an 

exclusion for its wheel hub bearings. An exclusion will prevent Polaris from incurring additional 

costs while it is actively re-sourcing the product. See section C below. 

C. Impact on Polaris (Question 11) 

In order to accomplish this re-sourcing, Polaris will incur [ ]. Polaris estimates 

that the cost to re-source the wheel hub bearings in question will be approximately$[ ] 

for tooling and$[ ] for resources, including Polaris engineering, supplier quality, and 

purchasing. While Polaris is willingly incurring the costs to re-source away from a supplier in 

China, it seeks to avoid the additional tariff-related costs that otherwise would be incurred during 

the re-sourcing process. 

Section III contains additional information concerning the impact on Polaris of the Section 301 

duties. 

D. Information about Intellectual Property and Made in China 2025 

Polaris has been using the same wheel hub bearing design and manufacturing methods for many 

years. Polaris' wheel hub bearings are ball bearings and are made of steel. The design of each 

wheel hub bearing is vendor owned. These are not products implicated by China's "Made in 

China 2025" policies. Polaris is not aware of any specific technology being developed in China 

that will advance the use of ball bearings or eliminate the use of bearings in our products. 

E. Draft CBP Language 

Polaris believes that CBP can easily exclude the wheel hub bearings in question based solely on 

the USHTS code given that wheel hub bearings are specifically classified at the 10-digit level of 

USHTS 8482.10.5024 for wheel hub angular contact ball bearings, not flanged, for use in 

production of vehicles. 

4 
Polaris - Addendum for Wheel Hub Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

III. Polaris Requests that USTR Mitigate the Adverse Impact of the Section 301 

Retaliatory Duties on U.S. Manufacturers 

A. Polaris is a Proud U.S. Manufacturer and Supports the Administration's 

Efforts to Create Free and Fair Trade 

Polaris is proud to be part of the storied history, and promising future, of U.S. manufacturing. 

We employ over 9,000 Americans, including 5,800 manufacturing workers, and willingly 

shoulder the responsibility of preserving their jobs and, through growth, creating even more. We 

pay competitive wages, [ J 

and grant stock to our employees, making our employee stock ownership plan Polaris' fourth 

largest shareholder. 

Polaris exemplifies American manufacturing and pro-American sourcing. Polaris proudly 

manufactures vehicles and engines at six U.S. factories in Huntsville, Alabama; Anaheim, 

California; Elkhart, Indiana; Spirit Lake, Iowa; Roseau, Minnesota; and Osceola, Wisconsin. 

Polaris also buys from suppliers in the United States to make our vehicles and engines and sells 

Polaris vehicles to consumers through independent dealers throughout the United States. [ 

] We recently built the $190 million Huntsville plant and 

are currently constructing a $50 million distribution center in Fernley, Nevada. 

Polaris' history proves that manufacturing generates wealth, and we know that a strong 

production sector is the backbone of a flourishing economy. However, without free and fair 

trade, U.S. products find themselves at a disadvantage in a worldwide market rife with 

government subsidies and punitive tariffs. This Administration understands the necessity of fair 

trade. It is admirably working toward instituting modernized trade agreements that remove 

unfair barriers to free trade. Polaris steadfastly supports these policies, which will ultimately 

benefit U.S. workers and consumers, as well as their international counterparts. 

B. Polaris Is Affected by Section 301 Tariffs, But Some Foreign Competitors 

Are Not 

Current Section 301 tariffs have resulted in [ ] higher costs for many components and 

parts used for final assembly in Polaris' U.S. factories. These Section 301 impacts are in 

addition to the increased costs of materials and components resulting from the Section 232 

steel/aluminum tariffs and the EU's 25% retaliatory tariffs on our Spirit Lake, Iowa-produced 

motorcycles and Canada's 10% retaliatory tariffs on our Elkhart, Indiana-produced boats. 

The unfortunate irony is that Polaris - a U.S.-based manufacturer and powersports market leader 

- is substantially affected by the Section 301 tariffs, while foreign-based competitors -

manufacturing outside the United States - are not. [ 

5 
Polaris -Addendum for Wheel Hub Angular Contact Ball Bearing 

Units, Not Flanged (OEM) 

PUBLIC VERSION 

] 

C. Immediate Relief Is Needed 

The cost to Polaris of the currently-imposed tariffs and retaliatory tariffs is [ 

] 

[ 

] [ 

] 

Given the [ ] to Polaris' business, not shared by some of our foreign 

competitors, Polaris respectfully requests that USTR grant relief as soon as possible. 

IV. Confidentiality Statement 

Consistent with USTR's Section 301 notice, Polaris 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. 

6