Lutron Electronics Co., Inc. Sept. 20 2018

1. Status of Comments 

PUBLIC VERSION OF CONFIDENTIAL

2. Complete detailed description

3. Provide the 10 Digit HTSUS Number LIST 1 8536.50. 9050

4. Requestor Information

Name: Hakkarainen, Pekka

Organization Lutron Electronics Co.,Inc. 

Representative (STR)

5. Requestor Relationship 

IMPORTER

6. Additional Attachments 

YES

7. Additional Attachments contain BCI, Public, or Public Version of BCI

PUBLIC VERSION OF BCI

8. Is this product or a comparable product available from sources in the US?(circle or bold )

NO

9. is or comparable product available from a third country? 

NO

10. Provide the value of the Chinese import for the calendar year USD

2017 [REDACTED]

Fan control switches are inserted into junction boxes to replace conventional switches. Thefan control features 3-speed, Single or 

multi- pole access, and quiet operations. The switch controls one 120V AC, 1.5A ceiling paddle fan. The user interface is a single 

sliding knob used to adjust the speed of the controlled fan from off through 3 speeds using a slider knob. The device is available in 

several colors. It is packaged in plastic clamshell packaging. It is generally available in retail stores and local hardware stores as well 

as on line retail sites. The dimensions of the clamshell packaging is 15.5 cm height x 10.1 cm width x 22.2 cm depth. The weight is 

136 grams. The dimensions of the control is 5.3 cm x 5.4 cm x 10.5 cm (LxWxH). See Attached for additional detail.
2016 [REDACTED]

2015 [REDACTED]

10. Provide the quantity (eaches) for the calendar year

2017 [REDACTED]

2016 [REDACTED]

2015 [REDACTED]

11. Information in Support of Request

Please see the attachment


The Honorable Robert Lighthizer

20 September, 2018

Page 2

INTRODUCTION TO LUTRON

Lutron Electronics Co., Inc. of Coopersburg, Pennsylvania is a 57-year-old, family-owned 

and operated company. Lutron, a U.S. headquartered company who is the leader in our 

industry, provides lighting and shading control solutions to consumers that range from 

small business enterprises and home owners to large corporate, commercial and 

municipal buildings. Lutron has manufacturing locations in: Coopersburg, PA; Alburtis, 

PA; Fogelsville, PA; Ashland, VA; Austin, TX; and Humacao, Puerto Rico. [REDACTED]

[REDACTED] Lutron has a manufacturing facility in China at Lutron GL Electronics 

(Shanghai) Co., Ltd. (hereafter referred to as Lutron China). This China facility is not a 

joint venture nor is it a state-owned enterprise. The China operation manufactures goods 

to the standards set by the Lutron U.S. quality function. [REDACTED] 

Lutron Electronics Co., Inc., a Pennsylvania Corporation, develops and owns the 

intellectual property for the fan control switches that are the subject of this request. 

Research and Development for all Lutron products are exclusively undertaken in the 

U.S. By doing the research and development in one of our five U.S. engineering 

centers1, we strive to prevent the theft of our intellectual property while also maintaining 

strong controls over the end-to-end manufacturing processes and the high quality of our 

products. Lutron holds patents on many of its products. 

[REDACTED]

Lutron technology today contributes to saving more than $1 Billion in energy costs in the 

U.S. Lutron products reduce the need for new or re-furbished electric power plants by 

saving a minimum of 10 billion kWh of energy every year- and growing. The U.S. Energy 

Information Administration (EIA) estimates that in 2017, the U.S. residential sector and 

 

1 Coopersburg, PA; Boynton Beach, FL; Cambridge, MA; Philadelphia, PA; and Austin, TX.
The Honorable Robert Lighthizer

20 September, 2018

Page 3

the commercial sector used about 273 billion kilowatthours (kWh) of electricity for 

lighting. This was about 10% of the total electricity consumed by both of these sectors 

and about 7% of total U.S. electricity consumption. The EIA reported that electricity end 

use demand in all sectors will continue to grow, and published the below chart on 

February 6, 2018.2 The increasing demand for electricity underscores the importance of 

Lutron’s products in the residential and commercial sectors. 

Lutron’s products assist our consumers in managing energy cost within their own home 

or commercial building. The diagram below demonstrates how Lutron products located 

in home or residential buildings are part of the energy cost reduction across the entire 

complex power grid including substations, transformers and power lines that deliver 

electric power to consumers. When Lutron products are integrated with Lutron smart 

interface hubs consumers can optimally adjust lighting and shading solutions in the 

building. Lutron products may assist consumers in meeting federal and state energy 

consumption requirements as well as local residential and commercial code 

requirements. 

 

2 https://www.eia.gov/outlooks/aeo/
The Honorable Robert Lighthizer

20 September, 2018

Page 4

LUTRON FAN CONTROL SWITCH: HTSUS 8536.50.9050 

Lutron’s fan control switches are part of our wallbox offerings used in homes and 

commercial buildings, including Federal buildings. The fan control unit is approximately 

5.3cm long x 5.4cm wide x 10.5cm deep and is inserted into a junction box to replace a 

conventional wall switch. The unit is covered by a decorative faceplate that is generally 

sold separately from the fan control switch. These fan controls come in different styles 

and include a slider style switch. Lutron’s fan control products features 3-speeds and is 

a single pole control. [REDACTED] The slider contact travels over four sets of contacts 

to open or close a circuit. Contact is made by a rod sliding over a dual set of contacts. 

The user interface allows for easy - to - use adjustment of the fan speed with the touch of 

the slider. These switches are provided eo nominee in 8536.50.9050. As specified in 

this Tariff Number and the Explanatory Notes, they are devices for “making or breaking 

one or more circuits, or for switching from one circuit to another, for a voltage not 

exceeding 1000V”. They are referred to as single pole based on the single control 

location to control the fan unit. A picture of a Lutron fan control switch is provided below

as a reference: 
The Honorable Robert Lighthizer

20 September, 2018

Page 5

EXAMPLE PRODUCT: FAN CONTROL SWITCH

US COMPONENTS 

[REDACTED]

 

ASSEMBLY PROCESS IN CHINA

Lutron has a manufacturing facility in China at Lutron GL Electronics (Shanghai) Co., Ltd 

in order to be closer to certain components in our global supply chain. This China facility 

is not a joint venture nor is it a state-owned enterprise. The China operation 

manufactures goods to the standards set by the Lutron U.S. quality function. 

[REDACTED]

[REDACTED]

[REDACTED]
The Honorable Robert Lighthizer

20 September, 2018

Page 6

ADMINISTRATION BY CUSTOMS AND BORDER PROTECTION

Lutron supports the administration’s goal to protect America’s leadership in technology and 

innovation against China’s acts, policies and practices related to technology transfer, 

intellectual property and innovation. Lutron will facilitate the administration of this particular 

product exclusion using one or more of the following actions based upon the size and mode of 

the shipment, or other factors that may influence the movement of the particular excluded 

product. [REDACTED]

THE IMPACT OF THE TARIFFS

Section 301 Tariffs will negatively impact Lutron

Lutron Electronics Co., Inc., is a privately held Pennsylvania corporation and global 

manufacturer of lighting controls and window shades. The company has manufacturing 

and distribution facilities in Alburtis and Fogelsville, Pennsylvania; in Austin, Texas; in 

Ashland, Virginia; and in Humacao, Puerto Rico. [REDACTED]

Our manufacturing sites in the Lehigh Valley of Pennsylvania serve as an incubator for 

new design and process technology. Lutron Electronics Co., Inc., develops and owns 

the intellectual property that is used to manufacture these fan control products. 

Research and Development for all Lutron products are exclusively undertaken in the 

U.S. By making significant investment in research and development in one of our five 

U.S. engineering centers, we strive to prevent the theft of our intellectual property while 

also maintaining strong controls over the end-to-end manufacturing processes and the 

high quality of our products. The cost of these tariffs may reduce our ability to invest in 

new technologies in the U.S. because they exceed the corporate tax reduction benefit to 

Lutron from the Tax Cuts and Jobs Act of 2017. 
The Honorable Robert Lighthizer

20 September, 2018

Page 7

[REDACTED] The proposed tariffs are levied on Lutron’s products incorporating 

patented features developed in Lutron’s research facilities in the U.S.; therefore, 

manufacturers in foreign countries, other than China, have a competitive advantage over 

Lutron. 

Section 301 tariffs negatively impact consumers 

The primary purpose of this product family is to provide convenient, easy - to - use, in -

wall fan control switches, and to minimize energy costs for consumers. Tariffs on these 

fan control switches will significantly increase the cost of energy solutions that contribute 

to the U.S. becoming more energy independent through energy conservation. Lutron 

products reduce the need for new or re-furbished electric power plants by saving 10 

billion kWh of energy every year - and growing. These Lutron products are easy to 

install, and available for purchase by consumers in national retail chains and 

neighborhood hardware stores. The products provide both real energy cost reduction

and convenient solutions to home owners and renters. These tariffs negatively impact 

consumers’ ability to meet federal and state energy consumption requirements, as well 

as local residential and commercial building code requirements. Our customers, who 

include small to medium sized businesses, may have less money to re-invest in their 

businesses.

Some of our customers are small and medium sized businesses who are partners in our 

supply chain. Lutron may sell the subject products together with other Lutron product 

offerings for a project installation that creates an energy efficient solution for our 

customers. These projects involve multiple companies including dealers of electrical 

goods, construction companies specifying Lutron product, installers of electrical goods, 

electricians, and our logistics/supply chain partners who support the importation, 

transportation and delivery to the final work sites. The increase in costs by adding a tariff 

to this U.S. supply chain will ripple through many industries – heavily impacting the 

building/construction sector.
The Honorable Robert Lighthizer

20 September, 2018

Page 8

LUTRON IMPORT DATA

[REDACTED] These fan control switches are available in various colors to coordinate 

with the home or commercial space. The import trend for this particular product is shown 

below. 

Calendar Year Import Value Import Volume 

2017 [REDACTED] [REDACTED]

2016 [REDACTED] [REDACTED]

2015 [REDACTED] [REDACTED]

CONCLUSION

Lutron technology does not appear to contribute to: New information technology; 

Numerical control tools; Aerospace equipment; High tech ships; Advanced Railway 

equipment; Energy saving and clean energy Vehicles; Power Equipment; New materials; 

Medical devices; Agricultural machinery; Next generation IT; Advanced Rail 

Transportation Equipment; nor High-end Computer Numerical Controlled Machinery, 

Tools and Robots.

Lutron products do contribute to a reduction in energy costs for U.S. consumers. 

Lutron’s patented technology is the leader in the lighting industry for these types of 

products, however, this technology does not support achievement of the China 2025 

initiatives. In a July 2018 report, the U.S. Energy Information Administration reported 

that 87% of homes use air conditioning. This represents about 17% of the electricity

expenditure in the home using a 2015 cost base.

3

 According to the U.S. Department of 

Energy, Energy Saver, ceiling fans allow the temperature of a room to be increased by 

 

3 https://www.eia.gov/todayinenergy/detail.php?id=36692
The Honorable Robert Lighthizer

20 September, 2018

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four degrees with no reduction in comfort.

4 Lutron fan control switches offer cost 

conscious consumers options to reduce the cost of energy while providing a pleasing 

aesthetic in their home or commercial environment. 

Lutron supports the administration’s goal to protect America’s leadership in technology 

and innovation against China’s acts, policies and practices related to technology transfer, 

intellectual property and innovation. Lutron has implemented procedures and strict 

controls to protect its intellectual property and trade secrets for product that is 

manufactured in the Shanghai facility. We are requesting an exclusion for a particular

product that would not have any impact on convincing the Chinese to abandon their 

practice of IPR violations or trade secrets theft, nor are these products employing the 

technology China is seeking to meet its China 2025 goals. 

Lutron is actively reaching out to federal, state and local representatives wherever we 

have employees to ask for their support of this request. For the reasons cited in this 

letter, we respectfully request that the HTSUS 8536.50.9050 is excluded from the final 

version of USTR 2018-0025.

.

 

4 https://www.energy.gov/energysaver/home-cooling-systems/fans-cooling
The Honorable Robert Lighthizer

20 September, 2018

Page 10

ANNEX A 

HTSUS 8536.50.9050

1. SFSQ-FH 1.5Amp Single Pole 3 Speed Fan Control Switch

2. SFSQ-F Slide to Off Single Pole 3-Speed Fan Control Switch