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:

2017 Quantity:
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October 8, 2018 

VIA REGULATIONS.GOV PUBLIC

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

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Re: Request for Exclusion of Contact Relay Parts # 955931-00020, #955931-00023, # 955931-00025 and 

#955931-00034 from the Determination of Action Pursuant to Section 301 Tariffs 

Dear Ambassador Lighthizer, 

Aisin Electronics Illinois LLC (AEIL) respectfully submits this request for exclusion of these contact 

relays from the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1 The 

dimensions for these parts are 

• #95593100020 Dimension A 13.6 mm, Dimension B 12.0 mm and Dimension C 17.0 mm 

• #95593100023 Dimension A 21.6 mm, Dimension B 12 mm and Dimension C 8.8 mm 

• #95593100025 Dimension A 11 mm, Dimension B 12 mm and Dimension C 8.8 mm 

• #95593100034 Dimension A 21.6 mm, Dimension B 12 mm and Dimension C 8.8 mm 

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

1

 19 U.S.C. § 2411. 
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World Corp. of America, located in Northville Mich.is the location of our headquarters. In addition, our 

research and development capabilities can be found throughout the United States. 

AEIL manufactures electronic systems used to control products such as sunroofs, power sliding door 

systems, etc. (electronic parts). These parts are transferred to our customers, automotive OEMs in the United 

States to be assembled into vehicles. 

Our competitive strategy has always been to follow a global approach and establish our family of 

companies in the U.S.to support the U.S. domestic and U.S. import manufacturer base. 

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid to long range, our 

strategy in the United States is to squarely focused on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customer in the United States. For AEIL this is an investment for the future we gladly make. 

The product we cite in this 301 exclusion request is purchased from China because it meets our 

engineering requirements. We are unaware of any other source, in the United States or abroad, which can 

supply the same product to our specific needs and those of our OEM customers in the United States. 

We are constantly striving toward product improvement that will benefit consumers, and its emphasis on 

environmental sustainability, community involvement and employee life balance, Aisin consistently lives up to 

its motto: “For a Better Tomorrow.” 

This exclusion request addresses the contact relay classified under HTSUS subheading 8536.41.0050 

which are currently subject to the 25% additional Section 301 tariff. 
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In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2 AEIL provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China. 

The contact relay is a key component of our electronic assemblies. The product as required by our 

company is only available from China. Our U.S. customer specifications are exact and rigorous. The product is 

designed and developed to support the product design requirements. An extensive validation process is required 

for qualification of supplier and product. The requalification process includes qualification of supplier, 

qualification of pricing, design validation, production trials, customer approval and production launch timing. 

The estimated timing for this entire process is 54 weeks. 

AEIL is not aware of any immediately available U.S. or third-country sources for the same or 

comparable products. Furthermore, any supplier change would require at least one year of testing and 

customers’ requalification and approval. Nor are we aware of any emerging capacity in the United States which 

could immediately provide AEIL and our US customers with a validated product. For an automobile, the quality 

and consistency of materials and components are of the utmost importance because they can impact the vehicles 

quality, safety, and performance. 

In short, this product has met the final approval of our automotive partners and customers in the United 

States. The process to validate a new supplier will require extensive testing to validate the product, both for our 

purposes as well as our OEM customers. More importantly perhaps, as we noted above, there is significant risk 

involved with the quality and delivery aspects of this revalidation in terms of production schedules. 

2 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 Technology Transfer, Intellectual 

Property, and Innovation, 83 Fed. Reg. 32,181 (USTR July 11, 2018). 
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This particular product, as specifically configured to our production needs, is not available outside of 

China. The company’s U.S. operations would suffer economically if we were forced to locate an alternative 

supplier as this would engender significant delay costs, requalification assessment costs, and potential loss of 

our OEM customer. 

2. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requester or other US interests.

The contact relay is a key component of our automotive parts manufacturing and supports domestic 

manufacturing operations and U.S. jobs in the United States. The imposition of a 25% tariff on this product 

would cause severe economic harm to U.S. interests, including our employees, our customers, and consumers, 

who eventually will be paying higher prices for new vehicles. Specifically, any future business opportunities 

involving these products could be directly impacted by the price increase caused by the additional tariff. Our 

concern here is that the 25% tariff will impact the company’s production costs, reducing profit margins and 

therefore minimizing any future R&D investments, in the long-run negatively impacting production strategy. 

This will, in turn, adversely affect a broader spectrum of U.S. interests, including U.S. investments, and jobs. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or other 

Chinese industrial programs. 

The imposition of a 25% ad valorem duty on this contact relay from China will not impact the Chinese 

intellectual property violations they seek to eliminate. Section 301 tariffs are aimed at specifically targeted 

products that have benefitted from the China’s acts, policies, and practices detailed in the USTR’s Section 301 

Report. Made in China 2025 aims to promote their indigenous research and development capabilities. The 

contact relay is not a new technology. 
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We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted, 

Larissa V. Koursova 

Assistant General Manager, Purchasing 

Aisin World Corp. of America 

Phone +1 734 582 7654 

Mobile +1 248 756 9958 

lkoursova@aisinworld.com