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October 9, 2018 

VIA ELECTRONIC FILING PUBLIC VERSION 

The Honorable Robert E. Lighthizer Docket. No.: USTR-2018-0025 

United States Trade Representative 

Office of the United States Trade Representative 

600 17th St. NW 

Washington, DC 20508 

Re: Request for Exclusion from Section 301 Tariffs of Certain Platen Castings 

Dear Ambassador Lighthizer: 

 

On behalf of our client, Milacron LLC (“Milacron”), we hereby submit our exclusion request for 

certain platen castings from the Section 301 tariffs enacted against products from the People’s 

Republic of China (“China”). These products have limited availability outside of China; none of 

which are identified in the “made in China 2025” program; and imposition of additional duties 

on these products would significantly undermine Milacron’s competitive advantage in both the 

U.S. and global market. 

For these reasons, Milacron respectfully requests that platen castings and related items imported 

from China, classified under HTS 8477.90.2540 be excluded from the final section 301 tariff list. 

A detailed list of Milacron imported platen castings are provided herein: 

I. Background 

Milacron is a global leader in the manufacture, distribution and service of highly engineered and 

customized systems within the $27 billion plastic technology and processing industry. Milacron 

is the only global company with a full-line product portfolio that includes hot runner systems, 

injection molding, blow molding and extrusion equipment. We maintain strong market positions 

across these products, as well as leading positions in process control systems, mold bases and 

components, maintenance, repair and operating (“MRO”) supplies for plastic processing 

equipment and fluid technology. Our strategy is to deliver highly customized equipment, 

components and service to our customers throughout the lifecycle of their plastic processing 

technology systems. 

Identifier Product Description Part Number Net Weight (kg) Length (mm) Width (mm) Height (mm)

Platen 1 Moving Platen Casting C6000 11803595 119,500 5.500 5.200 1.950

Platen 2 Stationary Platen Casting C6000 11803644 118,200 4.938 4.710 1.870

Platen Other Moving or Stationary Platen Various 100,000 Various Various Various
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Milacron services a diverse range of industries and have longstanding relationships with many of 

our over 27,000 customers and leading market shares in North America, and in emerging 

markets, including China and India. 

Milacron has over 150 sales and manufacturing facilities globally (14 USA locations including 

Milacron’s largest manufacturing facility in Batavia, OH), with products sold in over 100 

countries across 6 continents. 

Milacron’s business segments annually source $500-$550 million worth of materials for our 

various product offerings from over 8,000 suppliers globally. The China based supplier account 

for less than 5% of the total global suppliers in number, but represents an estimated 15-20% of 

Milacron’s $500-$550 million annual material purchase in value. 

II. Cast Iron Parts Have Limited Availability Outside of China 

Milacron sources casting for platens and related items from suppliers in the U.S. and globally. 

These platen castings are classified under U.S. HTS code 8477.90.2540. Milacron is unable to 

source from very large casting over 100,000 kilograms (very large castings or VLC) from U.S. 

suppliers due to a lack of capacity in the U.S. for this sized castings. There are U.S. suppliers that 

produce smaller castings, but none have been identified that can produce VLC. 

The attached import data shows that more than 80% of imports to the U.S. of cast iron parts are 

sourced from China, which is approximately five times more than imports from all other 

countries combined. No other country can produce the amount needed for industrial 

requirements, the quality demanded by Milacron, and no U.S. supplier has been identified that 

can produce VLC. U.S. industry is also unable or uninterested to produce the VLC necessary to 

meet U.S. demand. Accordingly, China is the main international source that is able to supply the 

U.S. market in meaningful commercial quantities, and China suppliers can produce VLC. 

Even if Milacron was able to find alternative suppliers, sourcing outside of China is extremely 

risky and costly. Milacron has invested significant time and capital to build very strong business 

relationships with its Chinese suppliers, and these relationships are difficult to immediately 

replicate. Thus, Milacron’s supply chains cannot be shifted to different countries or facilities 

without compromising long term contracts, compliance to standards, and quality and value for 

machine tools. The proposed incremental Section 301 tariffs will force Milacron to search for 

and qualify non-Chinese manufacturers in countries where the capacity to produce these products 

at a high quality level has not yet been fully identified or developed. 

III. Additional Section 301 Tariff Will Drive up Costs and Impede Milacron’s Ability to 

Compete on an International Scale 

Milacron currently holds competitive advantage in the manufacturing of machine tools on two 

fronts: advanced technology and cost efficiency. While Milacron has created competitive 

advantage mainly by achieving a superior quality and performance, Milacron also strives to keep 

a lower cost structure when competing with its competitors. To do this, Milacron relies on the 

quality and the availability of parts and services supplied by upstream actors, such as cast iron 
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suppliers, to respond to customers’ demands and help lower costs. 

Milacron focuses on the operations which generate the highest added value and profitability from 

machine tools. Milacron sources VLC to manufacture specific models of machines, which 

required lengthy research, engineering and development efforts. VLC represents about [--------] 

of Milacron’s machine costs. There are no domestic sources for VLC and global capacity is 

significantly constrained leading to already high costs and long lead times. Any additional duty 

on such cast iron components — let alone a 25% percent duty -- would cause Milacron major 

financial harm and jeopardize Milacron’s ability to satisfy its contractual obligations to its 

downstream customers. 

In addition, escalated operating costs due to Section 301 tariffs on VLC would make Milacron 

less competitive on the international market. Milacron is one of the United States’ major 

producers and exporters of machines and machine tools to emerging industrialized markets. In 

2015, U.S. producers exported over $8.1 billion worth of machinery to industrial end-users in 

markets around the world. It is estimated that exports of machines and machine tools will rise at 

a strong annual rate. 

Milacron operates in global markets where competitors outside the United States will use the 

same parts and manufacture outside the United States, and then import the finished products into 

the United States and emerging markets – all without tariffs while directly competing with U.S. 

manufacturing. When Milacron sells machines and machine tools in the United States and/or 

other countries, Milacron will do so with a higher cost structure than Milacron’s competitors 

(European and Asia manufacturers) producing outside the United States. This will place 

Milacron at a competitive disadvantage both in the United States and in Milacron’s export 

markets. In turn, this will only increase the incentive to move production and jobs out of the 

United States in order to remain competitive and place U.S. manufacturing at risk. 

IV. Additional Tariffs Would Have Adverse Impact on U.S. Economy and National 

Security Interest 

Machines and machine tools incorporated with Chinese VLC and cast iron parts are cornerstones 

for automotive, aerospace, medical, home appliance, construction, and other heavy industries. 

They are used in the production of crucial mechanical parts and components such as bodies, 

engines, gear boxes and powertrains for the automotive industry; the production of high 

precision 3D parts for the aerospace sector; and for manufacturing high precision implants, 

surgical instruments and precision components for the medical engineering industry. Machine 

tool consumption in the United States totaled $8.142 billion in 2017, an increase of 6.8 percent 

from 2016. A robust domestic manufacturing industry for machine tools is critical to the U.S. 

economy. 

Because the machine tool industry is a technology-intensive sector, it requires the employment of 

a highly skilled workforce. Such a workforce includes workers with degrees in engineering, 

software development, electronics, and mechanical processes in order to provide service to 

customers or to engage in R&D. Allowing VLC components to be excluded from Section 301 

will create a significant opportunity to retain and add such highly skilled jobs in the U.S. 
PUBLIC VERSION 

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throughout the supply chain. These are the types of jobs the United States needs to protect. 

Finally, machines and machine tools built using VLC components are important for U.S. national 

security because they are used to manufacture defense articles such as aircraft, armor, weapons, 

munitions, vehicles, and heavy equipment for the armed forces. In 1983, the National Machine 

Tool Builders’ Association filed a petition with the Secretary of Commerce under Section 232 of 

the Trade Expansion Act of 1962 requesting quotas on certain U.S. imports of metalworking 

machine tools. The Secretary made an affirmative finding that imported machine tools threaten 

to impair U.S. national security. After considering mobilization, defense, and economic planning 

factors, the President announced in 1996, that voluntary restraining agreements would be sought 

with Japan, Taiwan, West Germany, and Switzerland. The President also announced the 

implementation of the Machine Tool Domestic Action Plan to support the revitalization of the 

U.S. metalworking machine tool industry. Milacron responded to this action by expanding R&D 

and U.S. production of machines and machine tools with sourcing basic components such as cast 

iron only. If additional Section 301 tariffs are imposed, it would adversely impact how much 

U.S. machine tool builders, including Milacron, would spend on capital, on R&D, and on 

production in the United States. This would significantly impact the ability of the United States 

to remain ahead in the, machine building, aerospace and other defense-related industries, as there 

are few companies within the U.S. producing VLC and cast iron components that can be 

incorporated into machine tools. 

V. The Cast Iron Parts are Not Identified in “Made in China 2025” Plan 

Milacron invests significantly in the machine tool industry and understands the administration’s 

goal of protecting the intellectual property rights and trade secrets of U.S. companies operating 

in China; however, imposing Section 301 tariffs on VLC from China would not be practicable or 

effective to eliminate China's unreasonable and discriminatory acts, policies, and practices 

identified by USTR in its report in this investigation. The machine tool industry is a technical 

and technology-intensive sector. Innovation and capitalizing on knowledge-intensive, high value 

activities are the only way for Milacron to remain competitive in global markets. However, VLC 

play no role in the innovation of machine tools. VLC are not part of the “Made in China 2025” 

Plan. Indeed, the Chinese plan aims at developing the following advanced products and parts: 

1). Major products: 

a. Electronic information processing equipment: Focus on the development of 

20000 ~ 60000 r / min high-speed drilling center, five-axis linkage high-speed 

machining center, PSA paste machine and robotic assembly and inspection lines. 

b. Aerospace large structural parts manufacturing and assembly equipment: 

Focus on the processing of aluminum, magnesium, titanium, high-temperature 

alloy and other sophisticated materials with the application of multi-axis linkage 

gantry CNC milling machine, five-coordinate mirroring machine tool, robot 

cluster automatic drilling riveting, composite material automatic laying/sanding, 

multi-dimensional friction welding, super plastic/diffusion forming, precision 

controlled heat treatment, structural fatigue and bearing capacity test equipment, 

large aircraft and large rocket digital assembly. 
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c. Key equipment for aero engine manufacturing: Focus on the development of 

horizontal machining centers, turning and milling centers, boring machines, 

internal and external grinding machines, heavy-duty inertia friction welding, 

rolling forming, single crystal casting, high temperature vacuum heat treatment, 

surface strengthening, laser microporous forming equipment for key components 

such as blades, impellers, turbine disks, casings, and spindles. 

d. Key manufacturing equipment for marine and offshore engineering equipment: 

Key development of ship and offshore high-strength steel sheet single-sided 

welding double-sided forming (FCB), curved segment flexible support, highpower laser hybrid welding, multi-point pressure forming and other plane and 

curved segmentation line critical equipment; large diesel engine block, crankshaft 

, advanced processing and forming equipment such as gears, blades and offshore 

racks; and water-deep welding equipment with a depth of more than 1000 meters. 

e. Complete set of processing equipment for key components of rail transit 

equipment: Focus on the development of high-efficiency laser/stirred friction 

welding equipment for aluminum-magnesium alloy/stainless steel body, core 

manufacturing equipment for 30-ton axle heavy-duty electric locomotive, mobile 

high-speed welding equipment above 120Km/h, gears for trains with speeds 

above 350Km/h, lightweight machining and forming equipment such as bearings, 

wheel sets, bogies, and brake systems. 

f. Automobile key parts processing equipment and production line: Focus on the 

development of high-efficiency machining/near-net forming equipment and group 

production lines for automobile engines/gearboxes; development of diesel highpressure common rail, automotive safety, low-cost ultra-high-strength 

steel/aluminum alloy/carbon fiber automotive parts; and new energy vehicle 

electromechanical coupling systems, efficient processing and forming, on-line 

inspection and assembly equipment. 

g. Automobile four major process assembly line: For medium and high-end 

models, focusing on the application of ultra-high-strength steel/aluminum 

alloy/carbon fiber lightweight high-strength materials; development of 

lightweight hybrid materials, servo stamping/molding based on domestic robots, 

and efficient connection (laser welding, riveting, bonding) ), environment friendly 

energy-saving coating, digital robot assembly and other production lines. 

h. Large-capacity power equipment manufacturing equipment: Focus on the 

development of high-quality casting of millions of kilowatt-class nuclear power 

main pumps, complete sets of gas turbine welding rotor manufacturing 

equipment, robot welding complete sets of millions of kilowatt turbines, precision 

manufacturing equipment for ultra-high voltage power transmission and 

transformation equipment, and digital assembly equipment. 
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i. Engineering and agricultural machinery production line: Focus on precision 

machining equipment and complete production lines for engineering and 

agricultural machinery engines, gearboxes, high-pressure and high-flow hydraulic 

systems, as well as robot-based production lines for welding, painting and 

assembly. 

2). Additive manufacturing equipment: Focus on breaking through the highefficiency additive manufacturing process, complete sets of equipment, special 

materials and engineering key technologies of high-performance large-scale key 

components such as titanium alloy, high-strength alloy steel, high-strength 

aluminum alloy, high-temperature alloy, non-metal engineering materials and 

composite materials. Develop laser, electron beam, ion beam and other energydriven mainstream process equipment; overcome bottlenecks such as material 

preparation, print heads, and intelligent software to build an industrial chain. 

3). High-grade CNC system: Focus on the development of multi-axis, multichannel, high-precision interpolation, dynamic compensation and intelligent 

programming, intelligent CNC system with self-monitoring, maintenance, 

optimization, reorganization, etc.; provide standardized basic platform, allowing 

developers, different software and hardware modules intervention, an open CNC 

system with standard interfaces, modularity, portability, scalability and 

interchangeability. 

4). High performance parts: Focus on the development of 20,000 to 40000r/min 

high-speed electric spindles, multi-axis linkage spindle heads, precision gratings, 

high-precision spindle bearings, 1-2 ball screw guides, turntables with positioning 

accuracy less than 6”, etc. Develop complete sets of equipment for high 

performance parts processing, forming, testing and assembly. 

As such, VLC cast iron components are not listed as one of the strategic advanced technology 

manufacturing initiatives in the “Made in China 2025” plan. Milacron’s suppliers are not among 

those that benefit from the Chinese Government's acts, policies or practices identified by USTR, 

as being unreasonable or discriminatory and that burden or restrict U.S. commerce. Milacron has 

affiliates operating in China. Neither Milacron nor its affiliates have been forced to turn over any 

intellectual property rights, and innovation control to Milacron’s Chinese suppliers. The abovementioned longstanding relationships between Milacron and its Chinese suppliers have allowed 

Milacron to rely on dedicated suppliers that have an economic incentive to maintain lasting 

productive relationships and therefore properly maintain and protect intellectual property and 

trade secrets.

 

****** 

We have redacted certain business confidential information contained in this exclusion 

request and the accompanying exclusion form. Milacron certifies that the data include, inter 

alia, business trade secrets, commercial or financial information and certain other 

information, the disclosure of which would endanger trade secrets or profitability, and that 
PUBLIC VERSION 

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the information would not customarily be released to the public. Nevertheless, Milacron has 

provided a public version of this submission which can be placed in the public file for 

inspection. 

Please direct any questions concerning this submission to the undersigned. 

Respectfully Submitted 

Daniel Cannistra 

Yun Gao 

Counsel for Milacron 
PUBLIC VERSION 

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    Appendix 

2017 2018 YTD

2016 2017 2017 YTD  2018 YTD  2016 2017 2017 YTD  2018 YTD  2016 2017 2017 YTD  2018 YTD 

China  84669315 33,408,400 39,368,575 18,828,338 26,008,861 27,407,609 30,704,608 14,843,327 18,127,050 1.22 $               1.28 $            1.27 $             1.43 $             82.36% 84.24%

Thailand  84669315 3,958,194 5,709,694 2,138,017 2,864,806 3,021,603 4,570,083 1,889,972 1,748,673 $               1.25 1.31 $            1.13 $             1.64 $             12.26% 8.13%

Korea  84669315 1,028,085 1,089,623 571,178 1,035,596 349,406 435,389 215,178 395,212 $               2.50 2.94 $            2.65 $             2.62 $             1.17% 1.84%

Germany  84669315 1,701,130 627,822 240,538 3,221,770 182,404 49,679 18,319 354,025 $               12.64 9.33 $         13.13 $           9.10 $             0.13% 1.65%

Taiwan  84669315 1,148,992 1,064,105 638,550 649,240 331,058 358,545 247,684 228,777 $               2.97 3.47 $            2.58 $             2.84 $             0.96% 1.06%

India  84669315 24,450 297,198 293,428 231,009 11,833 34,034 33,987 208,840 $               8.73 2.07 $            8.63 $             1.11 $             0.09% 0.97%

Italy  84669315 712,368 661,712 201,333 751,586 44,610 71,580 34,506 104,389 $             9.24 15.97 $            5.83 $             7.20 $             0.19% 0.49%

Japan  84669315 2,164,077 2,413,404 1,287,985 1,094,415 274,462 142,233 37,769 100,961 $               16.97 7.88 $         34.10 $           10.84 $           0.38% 0.47%

Mexico  84669315 228,141 461,449 264,224 276,954 77,293 128,559 57,994 100,045 $               3.59 2.95 $            4.56 $             2.77 $             0.34% 0.46%

Canada  84669315 448,111 1,452,386 761,500 447,416 132,002 211,612 66,485 62,650 $               6.86 3.39 $            11.45 $           7.14 $             0.57% 0.29%

Romania  84669315 350,501 304,374 196,011 145,807 43,161 44,505 27,126 23,072 $               6.84 8.12 $            7.23 $             6.32 $             0.12% 0.11%

Sweden  84669315 75,577 132,673 65,926 168,974 18,366 31,988 1,481 18,051 $               4.15 4.12 $            44.51 $           9.36 $             0.09% 0.08%

Switzerland  84669315 1,643,575 402,501 266,402 499,234 105,806 41,542 27,091 15,121 $             9.69 15.53 $            9.83 $             33.02 $           0.11% 0.07%

Austria  84669315 25,330 7,054 0 53,726 8,363 12 0 13,607 $               587.83 3.03 $       NA 3.95 $             0.00% 0.06%

Argentina  84669315 0 0 0 12,192 0 0 0 8,128 NA NA NA 1.50 $             0.00% 0.04%

Slovak Republic  84669315 23,607 205,409 8,023 50,609 84 7,961 13 3,975 $           25.80 281.04 $         617.15 $        12.73 $           0.02% 0.02%

Finland  84669315 86,340 210,573 0 108,814 15,147 7,674 0 3,678 $               27.44 5.70 $         NA 29.59 $           0.02% 0.02%

Poland  84669315 98,037 28,534 6,403 67,810 11,225 247 68 1,188 $               115.52 8.73 $       94.16 $           57.08 $           0.00% 0.01%

Denmark  84669315 7,483 51,830 2,199 31,249 71 23,441 1 602 105.39 $           2.21 $            2,199.00 $     51.91 $           0.06% 0.00%

Spain  84669315 2,868 2,016,830 10,354 9,598 17 388,253 405 465 168.71 $           5.19 $            25.57 $           20.64 $           1.04% 0.00%

Israel  84669315 60,413 34,536 34,536 18,813 810 11,671 11,671 338 74.58 $             2.96 $            2.96 $             55.66 $           0.03% 0.00%

United Kingdom  84669315 300,899 53,430 9,535 43,573 25,559 9,084 86 300 $             5.88 11.77 $            110.87 $        145.24 $         0.02% 0.00%

Brazil  84669315 11,972 13,249 9,851 11,911 225 139 122 132 53.21 $             95.32 $         80.75 $           90.23 $           0.00% 0.00%

Netherlands  84669315 11,886 0 0 8,933 21 0 0 95 566.00 $           NA NA 94.03 $           0.00% 0.00%

Australia  84669315 9,150 15,258 15,258 14,416 3 62 62 59 3,050.00 $        246.10 $       246.10 $        244.34 $         0.00% 0.00%

Singapore  84669315 5,611 96,200 0 6,102 14 3,602 0 56 400.79 $           26.71 $         NA 108.96 $         0.01% 0.00%

Slovenia  84669315 21,368 13,602 7,057 26,538 17 9 7 27 1,256.94 $        1,511.33 $    1,008.14 $     982.89 $         0.00% 0.00%

Czech Republic  84669315 3,223 0 0 2,896 511 0 0 15 6.31 $               NA NA 193.07 $         0.00% 0.00%

Belgium  84669315 2,832 0 0 0 3 0 0 0 944 NA NA NA 0.00% 0.00%

France  84669315 41,917 99,028 55,731 0 8,397 869 433 0 4.99 $               113.96 $       128.71 $        NA 0.00% 0.00%

Ghana  84669315 8,664 0 0 0 5 0 0 0 1,732.80 $        NA NA NA 0.00% 0.00%

Hong Kong  84669315 223,208 12,600 2,700 0 145,598 1,807 1,357 0 1.53 $               6.97 $            1.99 $             NA 0.00% 0.00%

Hungary  84669315 0 9,800 0 0 0 1,378 0 0 NA 7.11 $            NA NA 0.00% 0.00%

New Zealand  84669315 21,214 12,083 7,676 0 122 60 42 0 173.89 $           201.38 $       182.76 $        NA 0.00% 0.00%

Turkey  84669315 0 2,788 2,788 0 0 11 11 0 NA 253.45 $       253.45 $        NA 0.00% 0.00%

Vietnam  84669315 5,600 0 0 0 1,040 0 0 0 5.38 $               NA NA NA 0.00% 0.00%

Total 47,863,223 56,868,320 25,925,541 37,862,848 32,216,845    37,280,637   17,515,197   21,519,531

8466.93.15

In Actual Dollars

for ALL Countries

U.S. Imports for Consumption

Annual + Year‐To‐Date Data from Jan ‐ Jun

In Actual Units of Quantity

Country  HTS Number  Customs Value ($) Quantity (KG) Unit Price ($/KG)
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 product of concern:

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

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.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

8. Is this product, or a comparable product, available from sources in the United States?:

VERSION 1

11. Please provide information in support your request, taking account of the instructions

provided in Section B of the Federal Register notice (note: text entered below can extend

beyond the apparent size of this box).

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

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

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