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
PUBLIC VERSION 

Confidential information 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 Technology Transfer, Intellectual Property, and Innovation (USTR-2018-0025) 

Aluminum Escalator Steps 

October 9, 2018 

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

systems, with its U.S. headquarters in Morristown, 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 is currently the only company that manufactures all of its commercial 

escalators domestically, producing approximately [ ] at its Clinton, North 

Carolina manufacturing plant. This facility produces approximately [ ] of commercial units 

sold in the United States. The Clinton, North Carolina facility has been in operation for more 

than 25 years, with approximately 200 employees and a 38,000 square foot escalator step facility 

and a 155,000 square foot escalator assembly plant. The plant received accolades throughout the 

years, including recognition as one of America's best plants. 

https :/ /www.businesswire.corn/news/home/201 0093 000654 2/ en/Schindler-Plant-Celebrates-20-

Y ears-CI inton-N C. 

The aluminum escalator steps that are the subject of this request are manufactured in 

China by [ 

]. [ ] is not a state-owned enterprise, nor is it a joint venture with any 

Chinese privately held or state-owned enterprises. Furthennore, [ ] is not 

affiliated with the Chinese government in any way, and the Chinese government derives no 

benefits from Schindler China. [ ] and its third-party vendors are also not subject 

to forced intellectual property or technology transfers. [ 

] . 

While Schindler has been exploring the possibility of sourcing aluminum escalator steps 

from U.S. and third-country manufacturers, it has so far been unable to do so for several reasons. 

First, there are currently no U.S. manufacturers of the type of aluminum escalator steps that are 

the subject of this request. Second, it is unlikely that alternative sources of supply will develop 

in the United States even with the added economic incentive of the tariffs. The [ 
PUBLIC VERSION 

Confidential infonnation of Schindler Elevator Corporation is redacted 

]. Schindler estimates that to develop a facility 

to produce aluminum escalator steps would cost approximately $8 million to $10 million. By 

contrast, [ 

]. Even if one assumes that such a new facility were to make a rate 

of return of 5-10% [ ] on such sales (an assumption that is ve1y 

optimistic), it is plainly uneconomical for a company to invest the significant resources that 

would be required to develop new production of escalator stairs in this country. 

Schindler is currently unable to source these steps from third countries [ 

]. [ ], any potential third-country suppliers of escalator steps 

currently lack the economic incentive to add new production because [ 

]. 

Furthennore, even assmnmg [ 

things, Schindler would need to [ 

with Schindler's own [ 

]. Among other 

] . In combination 

] . Meeting these 

standards is very important for Schindler's escalators, which are designed to transport large 

numbers of people safely and efficiently. 

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

escalator steps 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 tum, 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 aluminum escalator steps from China classified under the USHTS code 

and product description set forth herein.