September 21, 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 20006 

Re: Request for Exclusion from Section 301 Tariffs of Automobile Trunk Opener 

Switches 

Dear Ambassador Lighthizer: 

 

On behalf of Valeo North America, Inc. (“Valeo”), we hereby submit our exclusion request for 

certain trunk opener switches from the Section 301 tariffs enacted against products from the 

People’s Republic of China (“China”). These products are not economically and commercially 

available outside of China; none of these switches are high-tech products that are benefiting from 

the “made in China 2025” program; and imposition of additional duties on these products would 

significantly undermine Valeo’s competitive advantage in both the U.S. and global market. 

For these reasons, Valeo respectfully requests that trunk opener switches imported from China, 

classified under HTS 8536.50.9031, be excluded from the final section 301 tariff list. A list of 

detailed production descriptions is attached herein as Attachment 1. These goods could be 

described as: 

 Momentary Contact Push-Button Switches, comprised of at least a plastic housing, a 

rubber button cover, and spring, with switch face dimensions of 100 mm or less by 45 

mm or less, with a height of 30 mm or less, rated to between 9V and 16V, rated not over 

250 mA, and weighing not more than 50 grams 

Valeo hereby requests business confidential treatment for certain information clearly identified 

in brackets in the comments below, and in Attachment 1. Valeo 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 the 

information would not customarily be released to the public. Nevertheless, Valeo has provided a 

public version of this submission which can be placed in the public file for inspection. 

I. Background 

Valeo North America, Inc. is part of the Valeo Group. The Valeo Group is one of the world's 

leading automotive suppliers, providing a wide range of products to auto manufacturers and 
PUBLIC VERSION 

after-markets, including clutches, torque converters, engine cooling modules, climate control 

systems, lighting, wipers, and sensors, for most major car makers across the globe. The 

company’s innovative solutions are developed by four business groups - Powertrain Systems, 

Thermal Systems, Comfort and Driving Assistance Systems and Visibility Systems. The Valeo 

Group has 184 plants, 55 research and development centers, and 15 distribution platforms, and 

employs 111,600 people in 33 countries worldwide. 

Valeo has been serving the United States automotive market for 25 years. In North America, 

Valeo’s regional headquarters are located in Troy, Michigan. It has various offices, warehouses, 

production sites and research and development centers across the United States in California, 

Indiana, Kentucky, Michigan, Mississippi, New Hampshire, Ohio, Texas, Tennessee, and 

Virginia, and Valeo employs more than 14,000 people in North America. 

In 2017, Valeo generated sales of 18.6 billion euros and invested over 7% of its original 

equipment sales in research and development. Valeo’s sales are diversified across its operating 

segments, with Visibility Systems accounting for about 31% of the sales, followed by Thermal 

Systems (27% of revenue), Powertrain Systems (23% of revenue), and Comfort and Driving 

Assistance Systems (19% of the group's sales). In 2017, about half of its revenues were 

generated in Europe, followed by North America (20% of revenues), China (15%), the rest of 

Asia (16%), and South America (2%). 

II. Exclusion is Requested for the Increase in Demand and Lack of Commercial 

Availability Outside of China 

Valeo’s decision to import certain trunk opener switches from China is driven by our increased 

customer demand in the U.S. and globally. The imported products add complementary strengths 

to our existing production lines manufactured in the U.S. 

Valeo imports certain non-technically-sophisticated components from [ ] China to 

produce its value added auto parts. The companies in China that supply Valeo are not high-tech 

product producers, are not state owned companies, and their products simply are not among 

those identified as part of the “Made in China 2025” program that would 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. 

Valeo does not produce the imported trunk opener switches in the U.S. To the best of our 

knowledge, we cannot readily source the same or comparable products elsewhere in a 

commercially sufficient and cost-efficient manner. Nor can we increase our capacity fast enough 

to meet the increased demand of our customer. In order to qualify a new supplier, the 

automotive industry requires a Production Part Approval Process (“PPAP”). In general, a PPAP 

takes one to two years. Valeo would be unable to provide components from non-Chinese 

sources until the PPAP is complete, even if the tooling was moved from the current supplier’s 

facility to one of Valeo’s North American facilities. Without these importations, we would not 

be able to provide the full-range of products desired by our customers, and, as many customers 

desire the “one-stop-shopping” that a full range supplier affords, the 25% tariff threatens our 

supply of U.S. manufactured product to these customers. 
PUBLIC VERSION 

III. Imposition of Additional 301 Tariffs would Cause Severe Economic Harm to Valeo 

The additional 25% duties on Valeo’ imported trunk opener switches would significantly 

increase our production cost. As we operate in a global market, the increased cost would result in 

our foreign competitors having a significant competitive advantage over Valeo, because they will 

still be able to procure the same inputs from China without the 25% additional duty cost. This 

will make Valeo much less competitive in the global market and directly impact our ability to 

compete with foreign competitors. In turn, this will result in lost sales and, as a result, U.S. jobs. 

Further, the imported trunk opener switches are also critical inputs for our customers in the 

automotive original equipment manufacturer (“OEM”) industry. The 25% additional duty would 

adversely impact our automotive OEM customers by disrupting our supply chain and increasing 

costs. The additional duties would cause job losses due to a decrease in production if necessary 

parts and equipment are not available in a cost-effective manner. 

In addition, as discussed above, our imported Chinese products enable us to supply a full-range 

of switches desired by our customers. The increased cost would undermine our ability to 

continue offering our customers a complete line of OEM auto parts, which would result in lost 

sales. 

IV. Trunk Opener Switches Are Not Related to “Made in China 2025” or Other 

Chinese Industrial Programs 

Imposing additional 25% duties on the products that Valeo imports from China would serve no 

practical purpose to eliminate China’s unreasonable and discriminatory acts, policies, and 

practices identified by USTR in this investigation. Indeed, trunk opener switches are primary 

automotive products that require less sophisticated production technology. Valeo’s supplier’s 

facility is not a high-tech producer that was identified in USTR’s report. The products produced 

in these facilities were not identified by the USTR report. Our imported products are simply not 

among those that benefit from the “Made in China 2025” program, or any other Chinese 

Government’s acts, policies or practices identified by USTR as being unreasonable or 

discriminatory and that burden or restrict U.S. commerce. 

In addition, force-transfer of technology only exists in joint-ventures between a U.S. and a 

Chinese company. In this case, there is no joint-venture between Valeo and its supplier. The 

goods are purchased at arm’s length. As such, there is no forced transfer if technology between 

Valeo and its supplier. 

V. Conclusion 

Based on the reasons stated above, we respectfully request an exclusion of the trunk opener 

switches identified in the accompanying exclusion forms from the Section 301 tariffs because it 

would significantly increase Valeo operating cost and make us less competitive. The imported 

products are essential to completing our product line, and none of which are affected by the 

concerns cited by the USTR as justification for implementing the Section 301 tariffs. Tariffs on 
PUBLIC VERSION 

products that are not economically and commercially available to Valeo from U.S. producers 

will not advance national trade objectives and will be to the detriment of U.S. manufacturing. ****** 

Please direct any questions concerning this submission to the undersigned. 
PUBLIC VERSION 

ATTACHMENT 1 

Product Description List 

HTS Code Product Type Product Description Part Number Part Description 

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ ]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ ]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ ]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ ]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

[ 

]
PUBLIC VERSION 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]

8536.50.9031 Automobile Trunk 

Opener Switches 

Momentary Contact Push-Button 

Switches, comprised of at least a plastic 

housing, a rubber button cover, and 

spring, with switch face dimensions of 

100 mm or less by 45 mm or less, with a 

height of 30 mm or less, rated to 

between 9V and 16V, rated not over 250 

mA, and weighing not more than 50 

grams

[ 

]