Public Document

The exclusion request is for product number 1-0001-00016-001-05. The product is a Return Cap for use 

in the automotive industry. The dimensions of the product are 6 mm width x 12.707 mm length x 6 mm 

deep. The product is made of 17-4PH Stainless Steel. The 7501 Form submitted to CBP for this product 

states “Article of China” and includes the HTSUS subheading listed below. The product is shipped in 

wooden shipping crates labeled “CW Bearing” and the product number is printed on the packaging label.

8413919080

Click, Jay

CW Bearing USA, Inc. 

Nancy Noonan, Arent Fox LLP

Importer

YES

Public Version of BCI

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. 

I. Indicate whether the comment contains business confidential information (BCI), is a public 

document, or is a public version of a BCI document. 

I I 

2. Please provide a complete and detailed description of the product of concern: 

3. IO-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/ 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Note: Representatives submitting on behalf of an organization must enter information below. 

Requestor Representative: 

5. Requestor's relationship to the product: 

6. Does this submission in regulations.gov include additional attachments? 

7. 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 CONTINUED BELOW 1 
NO

NO

ˆ ˆ

ˆ ˆ

ˆ ˆ

* This is a new product that CW Bearing has not historically imported, but will import in 

the upcoming months due to previously planned production. 

We have requested a binding ruling from CBP to determine the proper classification of this 

product. Because we do not yet have the CBP's final determination, however, we have 

requested an exclusion for the 3 possible HTSUS subheadings for this product. 

As detailed in the articles provided at Exhibit 1, CW Bearing has invested heavily in 

domestic manufacturing, including through the establishment of a 50,000 square foot 

manufacturing and technical center in Northville, Michigan to manufacture steering and 

braking system components for the North American automobile industry. A letter of support 

from the Wayne County, Michigan Economic Development Corporation has been filed with 

this request at Exhibit 2.

Additional arguments in support of this exclusion request are attached.

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

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. 

2017 Value: 

2016 Value: 

2015 Value: 

2017 Quantity: 

2016 Quantity: 

2015 Quantity: 

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 bdow can extend 

beyond the apparent size of this box). 

VERSION 1 END 2 
 A Division of ISO 9001:2008 and ISO/IATF 16949 certified manufacturer Cixing Group Corp. LTD

AFDOCS/16912919.3 

October 5, 2018 

VIA REGULATIONS.GOV 

PUBLIC VERSION 

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 Return Caps and Retention Clips under HTSUS 8413.91.9080 

from the Determination of Action Pursuant to Section 301

Dear Ambassador Lighthizer: 

CW Bearing USA, Inc. (“CW Bearing”) respectfully submits this request for the 

exclusion of return caps and retention clips described in the attached Section 301 Investigation 

Form to Request Exclusion of Product from the proposed determination of action pursuant to 

Section 301 of the Trade Act of 1974.1

 

In accordance with the USTR’s instructions, we respectfully request that certain 

information contained in this submission, identified by brackets, be afforded business 

confidential treatment.2 The undersigned certifies that disclosure of the information identified in 

brackets in the confidential version of this submission would endanger the trade secrets and 

profitability of CW Bearing and would not customarily be released to the public. 

 

1

 19 U.S.C. § 2411. 

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, 32,183-84 

(USTR July 11, 2018) (“Procedures To Consider Requests for Exclusion”). 
PUBLIC VERSION Page 2 

AFDOCS/16912919.3 

CW Bearing was founded in 1994 in Tustin, California as a Sales and Engineering 

subsidiary of Cixi Group Co., Ltd. (“Cixi Group”). Our company has grown to become an $80 

million company with offices in Northville, Michigan, Tustin, California, and St. Louis, 

Missouri. In 2017, we launched CW Manufacturing, LLC, a 50,000 square foot manufacturing 

and technical center in Northville, Michigan to manufacture steering and braking system 

components for the North American automobile industry. Currently, CW Bearing and CW 

Manufacturing employ 54 people, with total employment impact expected to be over 150 by 

2022. Articles on our company’s extensive U.S. investment in Michigan are attached at Exhibit 

1. 

This exclusion request addresses return caps and retention clips classified under HTSUS 

subheading 8413.91.9080, which is currently subject to the 25% additional Section 301 tariff. A 

full description, including the physical characteristics, dimensions, and material composition of 

each product, as well as the ability of U.S. Customs and Border Protection (“CBP”) to administer 

this exclusion, is provided in the attached Section 301 Investigation Form to Request Exclusion 

of Product. Please note that a separate Form has been submitted for each unique part number for 

which we are requesting an exclusion. As previously noted, this is a new product that CW 

Bearing has not historically imported, but will import in the upcoming months due to previously 

planned production. We have requested a binding ruling from CBP to determine the proper 

classification of this product. Because we do not yet have the CBP's final determination, 

however, we have requested an exclusion for the 3 possible HTSUS subheadings for this 

product. 

In accordance with the procedures released by the Office of the United States Trade 
PUBLIC VERSION Page 3 

AFDOCS/16912919.3 

Representative (“USTR”),3 CW Bearing provides the following information requested by the

USTR in support of this request. 

1. Availability of the product outside of China, i.e. whether the particular product 

and/or a comparable product is available from sources in the United States and/or 

in third countries 

The return caps and retention clips that are the subject of this exclusion request is not 

available outside of China. Currently, our company sources these products from our parent 

company’s facilities in China. There is no readily available alternative U.S. or third country 

source outside of China from whom we can source these products. 

Our company is a subsidiary of Cixi Group, which is located in China. As a result, our 

U.S. business is required to utilize the corporate manufacturing facilities of Cixi Group in China 

for our return caps and retention clips requirements. Our parent company does not provide us 

with the option of switching suppliers and doing so is simply not an option for our company. 

There is also insufficient manufacturing capacity available in the United States to support 

domestic production. These factors make it impractical for us to relocate all our manufacturing 

operations to the United States. 

Moreover, we are unable to immediately switch suppliers for these products due to the 

extensive testing and approval required by our customers. The return caps and retention clips that 

we provide undergoes extensive testing, which takes, at minimum, several months, but can often 

take more than a year for final approval. Often our these products are used in safety related 

applications, such as steering and braking. This safety-critical end-use requires robust 

qualification, testing and validation processes, which is mandated by our customers and are a 

 

3 Id.
PUBLIC VERSION Page 4 

AFDOCS/16912919.3 

prerequisite to purchase in all cases. These requirements prevent our customers from 

immediately switching suppliers. Indeed, the lengthy approval associated with this product 

requires us to plan our sales targets several years in advance. Currently, we are targeting business 

for the 2020 and 2021 calendar years because it will take this amount of time to validate the 

product. 

For our company to relocate production to another third country would therefore require 

not only recertification by our customers, but also that our company purchase land, build 

factories, make capital investments in machinery, and develop a workforce. At minimum, this 

process would take 3 to 5 years to complete, not to mention extensive resources and serious 

supply and production interruptions. This process would negatively impact our downstream 

customers in the United States and, ultimately, American consumers. 

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

severe economic harm to the requester or other US interests

The imposition of a 25% tariff on return caps and retention clips causes severe economic

harm to our business and other U.S. interests, including supply and production interruptions for 

our downstream customers, as described above. CW Bearing is currently operating in a negative 

profit loss situation because of the additional tariffs. Before the 25% tariff was imposed, CW 

Bearing was investing heavily in our manufacturing operations in Northville, Michigan. With the 

implementation of the additional tariff, it no longer makes business sense for our company to 

continue investing in domestic manufacturing and we will cease further investment to our 

Michigan facility. Indeed, without an exclusion from the tariff, we will likely be forced to close 

our manufacturing operations in Michigan entirely, leading to the loss of 54 full-time jobs and 

the more than 150 high paying American jobs we were planning to create in Michigan by 2022. 
PUBLIC VERSION Page 5 

AFDOCS/16912919.3 

The imposition of the 25% tariff will make the price of our product uncompetitive, 

leading to a reduction in sales. We are already experiencing these negative effects in the few 

months the 25% tariff has been in effect. The implementation of the tariff will also have a 

negative indirect impact on the various local services we use to support our domestic operations. 

If we pass along the additional costs to our customers, it will likely make the price of their 

product uncompetitive and will lead to a reduction in their sales. 

The return caps and retention clips we import from China are used for an automotive 

braking application and support downstream manufacturing operations in the United States. 

Specifically, our company is a Tier 2 supplier to many of the major Tier 1 and OE manufacturers 

in the United States. We supply to many large U.S.-based companies, including [ 

]. We have spoken to many customers who agree with 

the representations by CW Bearing regarding why our product exclusion requests should be 

granted. See, for example, the letters from our customers attached at Exhibit 3. Our customers 

depend on a reliable supply of this product and there is no viable substitute because it is designed 

and tested specifically for each customer’s application. The 25% tariff will lead to higher prices 

for this essential product for our customers and ultimately for American consumers. 

As shown in the articles attached in Exhibit 1, CW Bearing’s commitment to U.S. 

manufacturing is exactly the type of foreign investment needed to bolster our nation’s economy. 

CW Bearing has established its headquarters for production in Michigan, but has also extensively 

invested in manufacturing operations in Ohio, supporting additional American jobs. The 

company is now run by a U.S. citizen, who seeks to continue growing our business in the United 
PUBLIC VERSION Page 6 

States. However, these prohibitively high tariffs will stifle CW Bearing’s intended investments 

and threaten our continued operations in the United States. Given this positive impact in the 

community the Wayne County, Michigan Economic Development Corporation has written a 

letter in support of this exclusion request, attached at Exhibit 2. 

3. Whether the particular product is strategically important or related to “Made in

China 2025” or other Chinese industrial programs

The return caps and retention clips at issue are not part of the “Made in China 2025”

initiative, nor targeted by any other Chinese industrial program. 

Return caps and retention clips are considered a low technology product, which support 

higher technology manufacturing. An important aspect of our business model is to use return 

caps and retention clips manufactured by the parent company in China in our U.S. 

manufacturing facilities. There are no intellectual property issues with the product our parent 

company manufactures in China. We did not switch from U.S. suppliers to suppliers in China, 

but rather have always used our parent company in China to supply these products. 

Indeed, CW Bearing’s technology originated in China. The intellectual property for the 

product at issue was not acquired from outside of China, but rather developed there. In fact, our 

company’s investment in the United States is a result of our Chinese parent company’s “know 

how” and technology, not technology originating in the United States. The 25% tariff on return 

caps and retention clips will therefore have no impact on the Chinese acts, policies, and 

practices they seek to eliminate. It will only put many domestic jobs and manufacturing growth 

in the USA at risk. 

AFDOCS/16912919.3 
PUBLIC VERSION Page 7 

AFDOCS/16912919.3 

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, 

 Jay Click 

___________________ 

 Jay Click 

 CW Bearing USA, Inc. 

 VP of North American Operations 
EXHIBIT 1

9/12/2018 Snyder - Gov. Rick Snyder: Chinese company to invest nearly $26 million in Northville Township facility

https://www.michigan.gov/snyder/0,4668,7-277--363571--,00.html 1/2

SNYDER

Gov. Rick Snyder: Chinese company to invest nearly $26

million in Northville Township facility

Aug. 31, 2015

Governor returns from trade mission promoting Michigan business, tourism

Gov. Rick Snyder and members of the Michigan delegation met in Beijing with Chinese Ministry of Commerce Vice Minister Zhong

Shan and leaders from his department and from representatives from Chinese provinces and one city prior to signing a pledge to

strengthen cooperation and expand economic activity between Michigan and China in hopes of boosting trade and investment, and

creating more and better jobs.

LANSING, Mich. -- A Chinese bearing manufacturer will invest nearly $26 million to establish a new U.S.

headquarters and technical center in Northville Township, creating 125 jobs, Gov. Rick Snyder said Monday after

returning from an eight-day investment mission to China.

Snyder met with leaders of CW Bearings, USA, Inc. in Shanghai on Saturday before his return to Michigan. It

was the final meeting in a week that included sessions with government leaders, businesses and journalists to

expand export markets for Michigan-made goods, increase investment in businesses located in the state and

promote Michigan as a tourism destination – all of which will create more and better jobs.

“CW Bearing’s decision to locate its U.S. headquarters in Southeast Michigan signals to corporate leaders

across the globe that the Great Lakes State offers great opportunities for their business expansion,” Snyder said.

“This comes as we return from a busy, productive week developing and strengthening relationships that will lead

to new investments, new export opportunities, and more jobs for Michiganders and our communities.”

CW Bearing, founded in 1984, has locations in California, North Carolina and Michigan. The company produces

bearing components used in electronic power steering systems that are gradually replacing hydraulic steering

systems.

The company plans to build a facility in Northville Township to house its U.S. headquarters, an engineering and

technical center, and advanced manufacturing operations. The project will generate a total capital investment of

OFFICIAL WEBSITE OF MICHIGAN.GOV

OFFICE OF

GOVERNOR RICK SNYDER
9/12/2018 Snyder - Gov. Rick Snyder: Chinese company to invest nearly $26 million in Northville Township facility

https://www.michigan.gov/snyder/0,4668,7-277--363571--,00.html 2/2

$25.9 million and create 125 jobs, resulting in a $550,000 Michigan Business Development Program

performance-based grant.

Michigan was chosen over competing sites in other states. Northville Township has offered support to the project

in the form of property tax abatement.

“CW Bearing and all of its employees want to thank the state of Michigan for this grant and the support in helping

us to make this project a reality,” said Jay Click, CW Bearing USA director of sales. “This facility, located in

Northville Township near the heart of the North American auto industry, will allow us to better support our

‘Customer First’ philosophy by increasing both our global manufacturing and technical capabilities, allowing us to

bring more value and versatility to our growing customers. “We look forward to continued support from the state

and local government as we continue to expand our operations in the state of Michigan.”

People interested in career opportunities with CW Bearings should visit this link on the company’s

website. http://www.cwbearing.com/careers.html.

During the investment mission, Snyder visited Beijing, Guangzhou, Shenzhen, Hangzhou and Shanghai, where

he promoted Michigan business opportunities by visiting with companies connecting with senior government

leaders.

He met with several automotive organizations including Chinese Association of Automotive Manufacturers and

China Council for the Promotion of International Trade Auto Committee, encouraging investment or export

opportunities for Michigan’s automotive industry.

Snyder also signed a memorandum of understanding between Michigan and representatives of four of China’s

provinces and one of its major cities. Michigan is one of only five states and cities to have reached agreement

with five industrial regions of China.

The agreement aims to strengthen friendly contacts between Michigan and each province or city. It enables the

jurisdictions to increase cooperation and carry out exchanges in industry and agriculture, economic activities and

trade, science and technology, culture and education, sports and health, travel and tourism, and other fields.

Snyder also met with journalists covering business and travel in Beijing, Guanzhou, and the Mutianyu section of

the Great Wall. He and Michigan Department of Agriculture & Rural Development Director Jamie Clover Adams

alsomet with Chinese agriculture officials to build upon relationships and cooperation, and boost exports of

Michigan’s high quality agriculture products known globally for their food safety.

Concurrent with the governor’s investment mission, the Michigan Economic Development Corporation led

business leaders from seven Michigan companies to China to meet with prospective business partners,

distributors and buyers to increase export opportunities from Michigan to China.

The eight-day mission covered an estimated 15,747 miles, including nearly 2,000 miles traveled within China.

The trip marks the Snyder administration’s fifth mission to China. Other missions led by Snyder or Lt. Gov. Brian

Calley have included Japan, South Korea, Canada, Germany, Italy, the Netherlands, Brazil, Mexico, Israel, Chile,

and Columbia.

#####
9/12/2018 CW Bearings kicks of N’ville Twp. headquarters

https://www.hometownlife.com/story/news/local/northville/2015/11/17/cw-bearing-groundbreaking-bob-nix-gov-rick-snyder-new-headquarters-northville... 1/2

CW Bearings kicks of N’ville Twp. headquarters

Joanne Maliszewski, hometownlife.com Published 12:22 p.m. ET Nov. 17, 2015

Northville Township officials, Gov. Rick Snyder and

leaders of CW Bearing USA on Monday celebrated

the groundbreaking of the Chinese ball bearing

manufacturer that will build invest approximately $26

million to build its American headquarters in

Northville Technology Park.

The company plans to bring some 125 new jobs to its new 50,000-square-foot

headquarters on 10 acres in the technology park at Five Mile and Beck road.

Working through the Michigan Economic Development Corporation, CW Bearing USA

will receive a six-year tax abatement and is expected to also receive a $500,000 state

performance grant for the project. The package of state and local incentives to bring

the manufacturer to Michigan totals $2.7 million, including the performance grant.

“We looked at a lot of different options,” said Jay Click, CW Bearing USA sales director.

That search included consideration of location, the proximity to transportation routes

and universities.

The acreage allows for the later expansion of potentially another 40,000 square feet,

Click said.

The technology park, developed by REDICO, includes 54 acres on the northeast

corner of Beck and Five Mile. The park is currently home to Techno Semichem, a

developer of lithium ion battery components; ZF Technologies, which develops

automotive hybrid drive trains; and IAV, an engineering and testing provider for the

automotive industry.

The company, which started in 1984 and is headquartered on the east coast of China,

develops and produces ball bearings for electrical motors, gearboxes, power tools and

the automotive industry. It’s among the 10 largest ball bearing producers in China.

When the facility is completed in Northville Township in late 2016, a small group of

existing employees will move from a 5,000-square-foot facility on Cabot Drive in Novi.

“The equipment will likely go in in early 2017. We will start to ramp up at the end of

2018,” Click said.

The new jobs, to be created over five years, are technical, manufacturing and

engineering jobs. “These jobs will support our sales,” Click said. “This gives us an

opportunity to bring jobs from China. We are really excited to bring job over here to

North America.”

CW Bearing was one of the businesses tapped by Gov. Rick Snyder during a trade trip

to China in August. During the investment mission, Snyder visited Beijing, Guangzhou,

Shenzhen, Hangzhou and Shanghai, where he promoted Michigan business

opportunities by visiting with companies and connecting with senior government

leaders.

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EXHIBIT 2
September 26, 2018 

Warren C. Evans 

Wayne County Executive 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Support for CW Bearing's Request for Exclusion of Bearings From the Additional 

Action Pursuant to Section 301 

Dear Ambassador Lighthizer: 

I am writing this letter in support of the product exclusion requests filed by CW Bearing 

USA, Inc. ("CW Bearing") in response to the 25% ad valorem tariffs on certain 

bearings imported from China. These products support extensive downstream 

manufacturing in the United States, including in my home state of Michigan. Given the 

negative impacts that implementation of such high tariffs will have on these products, I 

respectfully request that certain bearings imported under U.S. Harmonized Tariff 

Schedule ("HTSUS") 8482.10.5052, 8482.99.6595, 8482.99.0050, 8482.91.0040, 

8482.40.0000, 8482.10.5060, 8482.10.5056, 8482.10.5048, 8482.10.5044, 

8482.10.5028, 8428.10.5024, and 8482.10.5016 b~ excluded from the additional 

Section 301 tariffs. 

The 25% additional tariffs on these bearings will cause severe economic harm to U.S. 

interests, including American workers in communities like Northville, Michigan. In 

2017, CW Bearing opened a 50,000 square foot manufacturing and technical center in 

Northville to manufacture steering and braking system components for the North 

American automobile industry. CW Bearing's operations in Michigan provide much 

needed stable, middle-class jobs in the Northville community. Currently, CW Bearings 

employs 54 hardworking Americans, though that number is expected to grow to over 85 

by 2022. The imposition of such high tariffs on the bearing imports needed to support 

this domestic production, however, threaten CW Bearing's expansion plans. 

Wayne County Economic Development Corporation 

500 Griswold, 28th Floor, Detroit, Michigan 48226 
CW Bearing's commitment to U.S. manufacturing is exactly the type of foreign 

investment we should be encouraging in the United States. We should encourage 

companies to invest in the United States, not penalize them for doing so. An exclusion 

from these prohibitively high tariffs will ensure that CW Bearing's intended 

investments in Michigan come to fruition and that their manufacturing operations 

continue to thrive in the United States. 

I look forward to working with you to promote the continued success of CW Bearing in 

Michigan by excluding certain bearings described in CW Bearing s requests from the 

Section 301 tariffs. These exclusions will promote U.S. manufacturing and the creation 

of American jobs in our community. Thank you for your consideration. 

PIP 

Khalil Rahal 

Executive Director 

Wayne County Economic Development Corporation 

Wayne County Economic Development Corporation 

500 Griswold, 28th Floor, Detroit, Michigan 48226 
EXHIBIT 3
PUBLIC VERSION 

September 18, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Docket No. USTR-2018-0025 

Re: Support for CW Bearing USA, Inc.'s Request for the Exclusion of Ball Bearings from the 

Detemiination of Action Pursuant to Section 301 

Dear Secretary Lighthizer: 

[ ]is a customer of CW Bearing USA, Inc. ("CW Bearing"). We purchase certain ball 

bearings from CW Bearing's facilities in Northville, MI. We are writing this letter in support of 

CW Bearing's request for the exclusion of these ball bearings from the 25% tariffs pursuant to 

Section 301. The imposition of these 25% tariffs on our purchases of ball bearings from CW 

Bearing would cause significant harm to U.S. interests, including [ ]our employees, and our 

customers, while having little to no impact on the Chinese acts, policies, and practices they 

intend to eliminate. 

] We have been a regular customer of ball bearings 

from CW Bearing for ] 

CW Bearing imports certain ball bearings from its parent company in China. We use those 

bearings to produce

]The ball bearings that CW Bearings provides to our company have been extensively tested to 

ensure they meet our exacting quality and performance specifications. CW Bearings offers a full 

range of products that best meet our needs. 

We have worked with CW Bearing to ensure that the bearings they supply to us meet our 

technical requirements and are of consistent quality. CW Bearing supplies ball bearings that 

consistently meets our quality standards. We have found CW Bearing to be our best option for 

ball bearings given its technical capabilities and consistent quality. We have no immediately 

available alternative source for these products. Any disruptions to CW Bearing's supply of ball 

bearings will result in serious inefficiencies and increased costs for our business. 

The imposition of 25% tariffs on ball bearings significantly increases our costs. In 

anticipation of these high production costs, we are concerned for our business and our 

employees.

[ 

[ ] 

[ ]

[

]

[ ] 

[

]

[

[ ] 

[ ]

PUBLIC VERSION
PUBLIC VERSION 

I 

We respectfully request that the Department exclude ball bearings from the 25% additional Section 

301 tariffs. This exclusion will benefit U.S. businesses like I I and protect American 

manufacturing jobs. A reliable and reasonably priced supply of inputs like ball bearings is essential 

to American manufacturing and the continued production b lin the United 

States. 

[ 

]

[ ]

[ ]

[ ]

[ ] 

[ ]

PUBLIC VERSION
PUBLIC VERSION 

September 20, 2018 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Docket No. USTR-2018-0025 

Re: Support for CW Bearing USA, Inc.'s Request for the Exclusion of Ball Bearings from the Determination 

of Action Pursuant to Section 301 

Dear Secretary Lighthizer: 

[ lis a customer of CW Bearing USA, Inc. ("CW Bearing"). We purchase certain ball 

bearings from CW Bearing for our production facility in[ ' We are writing this 

letter in support of CW Bearing's request for the exclusion of these ball bearings from the 25% tariffs 

pursuant to Section 301. The imposition of these 25% tariffs on our purchases of ball bearings from CW 

Bearing would cause significant harm to U.S. interests, including[ ,Iour employees, and 

our customers, while having little to no impact on the Chinese acts, policies, and practices they intend to 

eliminate. 

[

]We have 

been a regular customer of ball bearings from CW Bearing for ] 

CW Bearing imports certain ball bearings from its parent company in China. We use those bearings to 

producelE iThe ball 

bearings that CW Bearings provides to our company have been extensively tested to ensure they meet 

our exacting quality and performance specifications. Replacing the bearings currently in use would 

require costly and long testing due to it significance regarding function and safety of our final product. 

This testing would take several months and would need to be carried out by CW bearingj

We have worked with CW Bearing to ensure that the bearings they supply to us meet our technical 

requirements and are of consistent quality. CW Bearing supplies ball bearings that consistently meets 

September 20, 2018 

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: Support for CW Bearing USA, Inc.’s Request for the Exclusion of Ball Bearings from the Determination 

of Action Pursuant to Section 301 

Dear Secretary Lighthizer: 

is a customer of CW Bearing USA, Inc. (“CW Bearing”). We purchase certain ball 

bearings from CW Bearing for our production facility in We are writing this 

letter in support of CW Bearing’s request for the exclusion of these ball bearings from the 25% tariffs 

pursuant to Section 301. The imposition of these 25% tariffs on our purchases of ball bearings from CW 

Bearing would cause significant harm to U.S. interests, including our employees, and 

our customers, while having little to no impact on the Chinese acts, policies, and practices they intend to 

eliminate. 

 We have 

been a regular customer of ball bearings from CW Bearing for

CW Bearing imports certain ball bearings from its parent company in China. We use those bearings to 

produce E . The ball 

bearings that CW Bearings provides to our company have been extensively tested to ensure they meet 

our exacting quality and performance specifications. Replacing the bearings currently in use would 

require costly and long testing due to it significance regarding function and safety of our final product. 

This testing would take several months and would need to be carried out by CW bearing, 

 

We have worked with CW Bearing to ensure that the bearings they supply to us meet our technical 

requirements and are of consistent quality. CW Bearing supplies ball bearings that consistently meets 

[

[

]

[

]

[ ]

[

]

[ ]

[ ]

PUBLIC VERSION

[

]

]

[ ].
PUBLIC VERSION 

[ 

our quality standards. We have found CW Bearing to be our best option for ball bearings given its 

technical capabilities and consistent quality. We have no immediately available alternative source for 

these products. Any disruptions to CW Bearing's supply of ball bearings will result in serious 

inefficiencies and increased costs for our business. 

The imposition of 25% tariffs on ball bearings significantly increases our costs. In anticipation of these 

high production costs, we are concerned for our business and our employees. Our company has[ 

]The rise in costs resulting from these 

tariffs will negatively impact our current business and future growth opportunities significantly. 

We respectfully request that the Department exclude ball bearings from the 25% additional Section 301 

tariffs. This exclusion will benefit U.S. businesses like[

land protect American manufacturing jobs. A reliable and reasonably priced supply of inputs like 

ball bearings is essential to American manufacturing and the continued production of [

] in the United States. 

Sincerely, 

[ 

E

our quality standards. We have found CW Bearing to be our best option for ball bearings given its 

technical capabilities and consistent quality. We have no immediately available alternative source for 

these products. Any disruptions to CW Bearing’s supply of ball bearings will result in serious 

inefficiencies and increased costs for our business. 

The imposition of 25% tariffs on ball bearings significantly increases our costs. In anticipation of these 

high production costs, we are concerned for our business and our employees. Our company has 

 The rise in costs resulting from these 

tariffs will negatively impact our current business and future growth opportunities significantly. 

We respectfully request that the Department exclude ball bearings from the 25% additional Section 301 

tariffs. This exclusion will benefit U.S. businesses like 

 and protect American manufacturing jobs. A reliable and reasonably priced supply of inputs like 

ball bearings is essential to American manufacturing and the continued production of 

 in the United States. 

Sincerely, 

[

[

[

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[ ] 

[ ] 

[ ] 

PUBLIC VERSION

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PUBLIC VERSION

October 5, 20 I 8 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F5 l 6 

Washington, D.C., 20006 

Docket No. USTR-2018-0025 

Re: Suppo1t for CW Bearing USA, lnc. 's Request for the Exclusion of Ball Bearings 

from the Determination of Action Pursuant to Section 30 I 

Dear Secretary Lighthizer: 

[ _ }s a long- standing customer of 

CW Bearing USA, Inc. ("CW Bearing"). We purchase certain ball bearings from CW 

Bearing's facilities in Northville, Michigan. We are writing this letter in support of CW 

Bearing's request for the exclusion of these ball bearings from the 25% tariffs pursuant to 

Section 301. The imposition of these 25% tariffs on our purchases of ball bearings from 

CW Bearing would cause significant harm to U.S. interests, including( ]our 

employees, and customers, while having little to no impact on the Chinese acts, policies, 

and practices they intend to eliminate. 

J . , _ _ ]is a subsidiary of the~ 1rhe 

[ - ]is a world-leading producer of outdoor power products for garcfen, park 

and forest care. Products include chainsaws, trimmers, roboti!c lawn mowers and ride-on 

lawn mowers. These products are sold under brands includin • 

. . ]via dealers an retailers to consumers and 

professionals throughout the United States. More infonnation can be found at 

[ J 

We have been a regular customer of ball bearings from CW Bearing for over 20 years. 

We use those bearings in production of chainsaws, trimmers and blowers for American 

professional lapdscapers and consumers at our production facility ir~ 

Jourl · · · ]operations emploY, approximately one thousand hard 

working American citizens across several locations in[ ) 

L ] 
PUBLIC VERSION

The ball bearings that CW Bearings provides to our company have been extensively 

tested to ensure they meet our exacting quality and performance specifications. Over time 

we have found the bearings supplied by CW Bearing consistently meet our quality 

standards. Therefore we have found CW Bearing to be our only option for ball bearings 

given its technical capabilities and consistent quality. 

[ ]has explored other sources for the bearings we purchase from CW. The 

challenge we encounter is either with insufficient capacity, lesser quality or both. As a 

result, we have no immediately available alternative source for these products. Because 

of this, CW Bearings best meet our needs for the range of products we source from them. 

Any disruptions to CW Bearing's supply of ball bearings may result in serious production 

interruptions at our facilities and given the seasonal nature of our business, subsequent 

loss of jobs and sales. 

We respectfully request that the Department exclude ball bearings from the 25% additional 

Section 301 tariffs. This exclusion will benefit U.S. businesses like{i , ]and protect 

American manufacturing jobs. A reliable and reasonably priced supply of inputs like ball 

bearings is essential to American manufacturing and the continued production of 

reasonably priced outdoor lawn and garden equipment in the United States. 

Sincerely, 

' 

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