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:
October 9, 2018

FILED VIA REGULATIONS.GOV

The Honorable Robert E. Lighthizer

U.S. Trade Representative

Office of the United States Trade Representative

600 17th Street, N.W.

Washington, D.C. 20508

RE: Request for Section 301 Exclusion

Docket No. USTR-2018-0025

Hand Tool Sets Containing Ratchet(s), Sockets, and Bits 

(whether or not also including adapters and extensions)

Classified in 8466.10.0175, HTSUS 

Dear Ambassador Lighthizer:

Apex Tool Group, LLC (hereinafter “ATG”) is submitting this exclusion request for 

certain hand tool sets pursuant to Docket No. USTR-2018-0025, 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. 32181 (Jul. 11, 2018). As detailed below, the tool sets at 

issue are not high-tech products that are strategically important to or related to the “Made in 

2025” or any other Chinese industrial programs. Moreover, they are not commercially available 

outside of our own factories in China and the imposition of an additional 25% tariff will cause 

serious economic harm to ATG, its retail customers, and American consumers. For these 

reasons, ATG respectfully requests that the tool sets specifically and narrowly described below, 

which are classified in subheading 8466.10.01 of the Harmonized Tariff Schedule of the United 
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 2 of 19

States (“HTSUS”), be excluded from Annex A of the USTR Notice published at 83 Fed. Reg. 

28710 (June 20, 2018) (“Annex A”). 

I. Overview of the Company

ATG is one of the largest manufacturers of professional hand and power tools in the 

world, serving the industrial, vehicle service and assembly, aerospace, electronics, construction 

and serious DIY markets. ATG maintains a portfolio of over 30 innovative brands 

including, GearWrench®, Weller®, Wiss®, Lufkin®, Cleco® and Crescent®. ATG also 

manufactures select, premier private label mechanics tools. Across the board, our tools stand for 

quality, innovation and value. Known for solving seemingly impossible problems, they are 

intuitive and simple to use, yet indispensable.

ATG works collaboratively with distributors, retailers and large customers across the 

globe to make sure end users have the tools they need to solve real-world problems. ATG is 

headquartered in Sparks, Maryland and employs approximately 1,800 people in the United States 

and another 6,400 people worldwide. We have manufacturing facilities and/or distribution 

facilities in Arkansas, Michigan, Ohio, Pennsylvania, North Carolina, South Carolina and 

Wisconsin. Our products are hand tools, power tools and electronic tools (described below). We 

provide these tools for various industries such as the industrial sector, vehicle repair, vehicle 

assembly, aerospace and the construction and do it yourself customers. ATG relies on imported 

components to produce many of its products here in the United States. In addition, ATG imports 

primarily lower value added finished goods from China and the vast majority [ ] of the subject 

tools sets from China are made at ATG-owned facilities.

Ratchets/drivers

The ratchets/drivers line consists of the business operations providing mechanic, trade, 

and specialty tools, chain, truck boxes, jobsite storage and drill chucks to a broad range of 

industrial, construction, vehicle repair and DIY customers worldwide.

Power Tools

The power tools line consists of the business operations providing electric tools, as well 

as high performance bits, torque measurement, metal cutting and drilling solutions to the
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 3 of 19

global industrial, vehicle assembly, aerospace and utilities/energy markets. To learn 

more, explore the Cleco Production Tools website.

Electronic Tools

The professional electronic tools line consists of the business operations providing 

precision soldering, cutting, motion control and air ventilation solutions to electronics 

assembly industries.

Our products are sold through national industrial distributors, contractor supply houses, 

automotive tool and equipment distributors, and many independent regional and specialized 

distribution partners. Certain consumer retailers, home centers and hardware stores also sell our 

private-label products alongside ATG brands.

II. Tool Sets at Issue: “Hand Tool Sets Containing Ratchet(s), Sockets, and Bits

(whether or not also including adapters and extensions) (classified in

8466.10.0175).”

The tool sets at issue contain ratchet(s), sockets, and bits. They may also contain 

extensions and adapters, which are attached to ratchets and drivers to permit better access to 

confined spaces and to allow them to accept different size sockets and bits. All the tool sets are 

packaged for retail sale at the time of importation. Typically, they are packaged in blow-molded 

plastic tool cases specially designed to fit the tools. A typical example of this tool set is the 

Husky 60-Piece Mechanics Tool Set (Model No. H10060MTS) depicted below:
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 4 of 19

This set includes 2 ratchets, 42 sockets, and 11 bits as well as 3 extensions and 2 adapters.

Annex A includes all products classified in the 8-digit subheading 8466.10.01, HTSUS. 

In its entirety, this subheading reads as follows (with the subject tool set provision highlighted in 

red):

To understand how these tool sets are classified, we first must understand how the 

ratchets/drivers contained in these sets are classified. By way of tariff schedule background, the 

vast majority of handtools are classified in Chapter 82, HTSUS. In fact, Chapter 82 is entitled 

“TOOLS, IMPLEMENTS, CUTLERY, SPOONS AND FORKS, OF BASE METAL; PARTS 

THEREOF OF BASE METAL.” Some of the handtools classified in this chapter include: 

• Heading 8201: Spades, shovels, mattocks, picks, hoes, forks and rakes; axes, bill hooks 

and similar hewing tools; secateurs and pruners of any kind; scythes, sickles, hay knives, 

hedge shears, timber wedges and other tools of a kind used in agriculture

• Heading 8202: Saws

• Heading 8203: Files, rasps, pliers, pincers, tweezers, metal cutting shears, pipe cutters, 

bolt cutters, perforating punches, and similar handtools

• Heading 8204: Hand-operated spanners and wrenches (including torque meter wrenches 

but not including tap wrenches); socket wrenches, with or without handles, drives or 

extensions
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Office of the United States Trade Representative

October 9, 2018

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• Heading 8205: Handtools (including glass cutters) not elsewhere specified or included: 

Blow torches and similar self-contained torches; Vises, clamps and the like; Anvils; 

Portable forges; Hand- or pedal-operated grinding wheels with frameworks; Drilling, 

threading or tapping tools; Hammers; Planes, chisels, gouges and similar cutting tools for 

working wood; Screwdrivers; Pipe tools: Crowbars; Caulking guns

• Heading 8206: Tool sets containing one or more of the tools described in the above 

headings.

• Heading 8207: interchangeable tools for handtools (e.g., bits).

The reason ratchets/drivers are not included in this chapter is due to a Chapter 82 Legal 

Note and interpretations of that Note by the courts and U.S. Customs & Border Protection 

(“CBP”). These can be summarized as follows:

A. Chapter Note 1, Chapter 82, HTSUS:

1. Apart from blow torches and similar self-contained torches, portable forges, 

grinding wheels with frameworks, manicure or pedicure sets, and goods of 

heading 8209, this chapter covers only articles with a blade, working edge, 

working surface or other working part of:

(a) Base metal;

(b) Metal carbides or cermets;

(c) Precious or semiprecious stones (natural, synthetic or reconstructed) on a 

support of base metal, metal carbide or cermet; or

(d) Abrasive materials on a support of base metal, provided that the articles have 

cutting teeth, flutes, grooves or the like, of base metal, which retain their identity 

and function after the application of the abrasive.

B. Judicial Interpretation:

Prior to the HTSUS, each country had its own tariff classification system. The United 

States had the Tariff Schedule of the United States (TSUS). In the mid 1980’s, the United States

adopted the HTSUS. However, prior to the change to the HTSUS, Note 1 to Chapter 82, 
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 6 of 19

HTSUS1, above was the subject of a court case by the U.S. Customs Court2in Continental Arms 

Corp. v. United States, 65 Cust. Ct. 80 (1970). The Continental Arms court, in classifying a

"valvespot oiler”, considered what constitutes a “working edge, surface or part” for purpose of 

headnote 1. After reviewing evidence proffered by both parties, the court decided that the term 

"working part" referred to "that part of the tool which does work in relation to a workpiece or 

object external to the tool." In applying its interpretation to the product at trial, the Continental 

Arms court found that the spout in the valvespot oiler was a passive conduit that did not work on 

an external object and was therefore not a "working part" of the oiler.

CBP has found that ratchet drives alone, without sockets or bits, do not have a “working 

part.” Accordingly, CBP has held they are excluded from Chapter 82, HTSUS. As ratchets 

“hold” sockets, CBP classified them as “tool holders” in subheading 8466.10.01, HTSUS. For 

one example among many, see Ruling HQ 967400 (3/29/06). CBP has applied the same 

reasoning to bit drivers as well as extensions and adapters for ratchet drives and bit drivers. They 

are all classified in subheading 8466.10.01, HTSUS, but fall under the “other” category of 

8406.10.0175, HTSUS.

If Note 1 had not been so interpreted by the Customs Court and CBP, these handtools 

would most certainly be classified in Chapter 82, specifically Heading 8205. Instead, they are 

classified in what is arguably a “second best” category covering tool holders. The “tools” these 

drives “hold” are sockets and bits, both of which are classified in Chapter 82. Under the above 

interpretations, the sockets and bits work on the fastener directly whereas the drivers work on 

them indirectly. This interpretation ignores the leverage and torque the drivers provide in 

tightening and loosening fasteners. One could argue the framers of the HTSUS would never have 

intended this result, but absent a Congressional act to modify the HTSUS or an interpretative 

change by the courts or CBP, such drives are not included in the handtool chapter. 

Tool sets may be classified in subheading 8466.10.01, HTSUS, pursuant to General Rule 

of Interpretation (“GRI”) 3(b) (according to the one tool in the set imparting the “essential 

 

1 The note at the time was Schedule 6, part 3, subpart E of headnote 1 of the TSUS, which is virtually the same note 

as found today in Chapter 82, Note 1.

2 The predecessor to the U.S. Court of International Trade.
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 7 of 19

character” to the whole set) or GRI 3(c) (where “essential character” cannot be determined, the 

set is classified under the one tariff provision that applies to all the components in the set that 

occurs last in numerical order in the tariff).

In the above example, Model No. H10060MTS contains the following tools: 

COMPONENT COMPONENT HTSUS HEADING QUANTITY

IN SET

Sockets 8204 42

Bits 8207 11

Ratchets 8466 2

Extensions 8466 3

Adapters 8466 2

In rulings involving tool sets comprised of the same or similar components, CBP has 

consistently held that the essential character of the set is imparted by the ratchet because the 

ratchet is the only component continually in use. See, e.g., Ruling HQ H96400 (Mar. 29, 2006)

(SKU 45785 classified in 8466.10.01 because the ratchet imparted the essential character); 

N250620 (Mar. 24, 2014) (socket/bit set classified in Heading 8466 because the handle was the 

only component continually in use). In the above representative set, it is the ratchets of Heading 

8466 that are the only components in continual use. As that component imparts the essential 

character, the entire set is classified in 8466.10.0175, HTSUS. 

This illustrates how entire tool sets can be excluded from Chapter 82, HTSUS, solely 

because they contain any number of ratchets/drivers. These tool sets are not industrial or 

machine tool holders or “self-operating die heads”, but handheld tools used by a broad crosssection of Americans including industrial technicians, contractors, tradesmen, auto mechanics, 

and serious do-it-yourselfers. 

We thought it would be helpful to contrast these tool sets with industrial tool holders and 

self-operating die heads that do fall under the targeted 8-digit subheading (8466.10.01, 

HTSUS). We have set forth below actual examples of those expensive, complex tool holders. 

ATG does not import them and has no opinion on whether they should be included in Annex A
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

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but merely includes them here to show the contrast between them and our low-tech “tool 

holders” – ratchets/drivers:

Source: http://techminy.com/wp-content/uploads/2016/12/Components-of-die-and-punch-Assembly.jpg

Self-Opening Diehead

http://www.plumberscrib.com/ridgid-97075-

815a-self-opening-die-head-right-handonly.html?gclid=EAIaIQobChMIioGL6Ie23AIVg

UCGCh0uagLREAQYCyABEgICb_D_BwE

Retail Price: $ 478.85
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 9 of 19

https://www.homedepot.com/p/Husky-3-8-in-Drive-100-Position-Universal-SAE-and-MetricMechanics-Tool-Set-60-Piece-H10060MTS/206034103

T-A® Spade Drill Insert Holders

https://www.travers.com/t-areg-spade-drillinsert-holders/p/71533/

Price Range: $ 185.01- $ 697.09

COMPARED WITH:
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 10 of 19

As you can see, these simple handtools are very dissimilar from the toolholders for which this 

tariff Heading is intended to cover. 

III. ATG Products Use Widely Available Manufacturing Technology

and Are Not a Part of the Made in China 2025 or Any Other

Chinese Industrial Program Initiatives

In the USTR’s Executive Summary of its Findings of The Investigation Into China’s Acts, 

Policies, And Practices Related To Technology Transfer, Intellectual Property, And Innovation 

Under Section 301 Of The Trade Act Of 1974 (3/22/18), it cited a plan published by the Chinese 

Government entitled Made in China 2025 (July 7, 2015). Hand tools are not one of the 10 

Priority Sectors identified by China in this plan. On page 23 of that plan, China outlined its 

objectives in the “High-end Digital Control Machine Tools and Robot” sectors:

3.6.2 High-end Digital Control Machine Tools and Robots

High-end Digital Control Machine Tools - We will:

• Develop precision machine tools capable of high speed, high efficiency 

and functional flexibility, and develop manufacturing equipment and 

integrated manufacturing systems.

• Accelerate research of frontier technologies and equipment like high-end 

digital control machine tools and additive manufacturing.

• Focus on reliability, stability and precision of major parts like high-end 

numerical systems, servomotors, bearings and grating to realize 

industrialization.

• Improve user process certification.

Robots – We will:

• Actively research new products and promote robotic standardization and 

market application modularization in order to meet demand for industrial 

robots in automobile, machinery, electronics, chemicals and light industry, 
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Office of the United States Trade Representative

October 9, 2018

Page 11 of 19

specialty robots and service robots in medical treatment, domestic 

services, education and entertainment.

• Remove the bottleneck of essential spare parts like robot bodies, 

reducers, servomotors, controllers, sensors, drivers and integrated system 

design.

Made in China 2025, State Council, July 7, 2015; at 23.

We suspect this was the basis for the USTR’s inclusion of subheading 8466.10.01, 

HTSUS, as there is no other industrial sector in this plan that would involve tool holders. The

simple handtool sets at issue are not high-end digital control machines or robots or parts of those 

machines. The technology used by ATG to make these simple handtool sets is not the “cuttingedge” technology that is being sought by China. Accordingly, we fail to see how inclusion of 

these tool sets in this Section 301 action would help the USTR meet its stated objective of

eliminating China’s policies on intellectual property rights acts, policies, and practices or 

disrupting China’s industrial economic goals described in Made in China 2025.

IV. China Never Attempted to Acquire ATG Technologies

ATG has never been restricted by the Chinese government in its manufacturing in China

and ATG would know because it is the main producer of these tool sets in China. For example, 

in 2017, roughly [ ] of ATG’s Chinese imports under subheading 8466.10.01, HTSUS, were

made at wholly foreign-owned enterprises (“WFOEs”) owned by ATG. Another [ ] were 

produced at one facility that is [ ] owned by ATG and [ ] owned by a Chinese partner. That 

was a purely business decision based upon land availability by the shareholder in exchange for a 

small ownership interest in the company. That silent partner has no operational involvement, nor 

has there ever been any technology transferred. Combined, nearly [ ] of ATG’s imports under 

this subheading are produced in ATG’s own facilities.

ATG can confidently state the Chinese government did not employ any tactics, such as 

opaque and discretionary administrative approval processes, joint venture requirements, foreign 

equity limitations, procurements or other mechanisms to regulate or intervene in our operations 

in China. Further, China did not require or pressure us to transfer any technology or intellectual 
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 12 of 19

property to Chinese company. The Chinese government’s acts, policies and practices did not

deprive our Chinese facilities of the ability to set market-based terms in licensing and other 

technology-related negotiations nor did it undermine our control over our technology in China. 

It has not been limited by required Chinese equity in manufacturing nor subject to various 

administrative reviews or licensing processes. The Chinese government has never directed nor 

unfairly facilitated the systematic investment in or acquisition of our assets or intellectual 

property. Finally, we are unaware of any data attacks or breaches by the Chinese government on 

any of our facilities or other attempts by the Chinese government to penetrate our computer 

networks and access sensitive trade secrets.3

Simply put, the Chinese government is not interested in our technology. Imposing tariffs 

on these tool sets would only harm U.S. interests, and would in no way influence or bring about 

the elimination of China’s acts, policies and practices that threaten IPR or trade secrets.

V. Severe Economic Harm to ATG and Other U.S. Interests 

The imposition of tariffs of 25% on the subject tool sets would cause severe economic 

harm to U.S. interests. These products constitute a large portion of our imported finished goods. 

China is the largest supplier in the world for all products included as “other” under 

8466.10.0175, HTSUS. As clarified earlier, the primary factories making these tools are ATGowned factories. Their production and employment are directly tied to and complement our U.S.

operations. Further, because of the machinery involved in crafting these tools, we cannot easily 

shift production to another country in which we currently manufacture, including the United 

States. The costs to shift production would increase manufacturing costs by at least [ ] which 

is above the 25% tariff. 

While we do manufacture our broad range of tools globally, most of the subject tool sets 

are manufactured in China and Taiwan. In addition, we also manufacture in the United States. 

 

3ATG’s primary systems are located in the US and have not been compromised, hacked or attacked. Our systems 

located in other Asian countries have the same protections as our U.S. facilities. ATG has never suffered a breach 

of its IPR protections. 
Ambassador Lighthizer

Office of the United States Trade Representative

October 9, 2018

Page 13 of 19

Importantly, ATG products with lower value-added manufacturing are centered in China

whereas higher value-added products are centered in the United States. Our ability to balance 

global manufacturing allows us to allocate costs across the various manufacturing scenarios to 

provide quality product at reasonable prices. 

In the United States, we manufacture:

1. Steel chain and accessories at our York, PA facility; 

2. Forging operations for chain and ratchets/drivers at our Sumter, SC facility;

3. Power tools and some torque wrench production that relies on imported Chinese 

components subject to the tariff at our Lexington, SC facility;

4. Delta truck boxes and jobox constructions storage boxes are made in our Jonesboro, AR

facility; 

5. Configure U.S. and German-made power tools into specific application fixtures for auto 

manufacturing plants in our Auburn Hills, MI facility;

6. Manufacture ATG brand bits and sockets for power tool applications in Dayton, OH; 

and

7. Special precision machining in our Walworth, WI facility.

ATG operations in the United States are already being negatively impacted by the steel 

tariffs imposed by the President under Section 232 of the Trade Act of 1962. Even though we 

use USA steel in our truck boxes and storage boxes, within three weeks of the tariffs being 

imposed on imported steel, our suppliers increased our prices by [ ]. The increase in

manufacturing already in the United States combined with increases of another [ ] for goods 

made globally will impact our ability to provide these tools, necessary for the construction, auto, 

industrial technicians, contractors, tradesmen and serious do-it-yourselfers. Our increased costs 

will be passed on to these vital U.S. industries and negatively impact their ability to use our tools 

and continue to build, make, and manufacture in the United States.
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Office of the United States Trade Representative

October 9, 2018

Page 14 of 19

The below graphic illustrates the economic harm ATG anticipates from these increased 

duties. As you can see, we estimate the American consumer will pay roughly $150 million more 

per year for tool sets classified in this tariff provision:

At the corporate level, ATG will suffer severe economic harm from the tariffs on these 

tool sets. These products are strong margin contributors to ATG - and contribute to the overall 

financial stability of the company. ATG estimates that the 25% tariff will be charged against 

approximately [ ] of these tools sets that Apex directly imports each year. This does not even 

include the value of these tool sets that Apex sells to its U.S. customers who import themselves.

The 25% Section 301 duties on this one subset of tool sets for Apex alone is estimated to be 

nearly [ ] annually. Worse, when all three phases of the Section 301 duties announced to date 

are considered, ATG alone faces nearly [ ] in potential additional duties each year. This is a 

severe, unanticipated expense that if fully implemented will cause serious economic harm to our 

company.

As the below graphic illustrates, a 25% increase will mean Americans will buy fewer 

items. The suppressed demand will erode profitability. Revenues will decrease, as will direct 
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Office of the United States Trade Representative

October 9, 2018

Page 15 of 19

investment. ATG employs roughly 1,600 associates in the United States and estimates a 10% 

drop in demand will result in a [ ] drop in U.S. investment and headcount.

VI. The Subject Tool Sets Are Not Commercially Available Outside of China

As illustrated in the below analysis that ATG prepared using 2017 Industry Point of Sales 

Data, production of the subject tool sets outside of China cannot meet the U.S. consumptive 

demand. Taking first all tool holder devices classified in 8466.10.0175, HTSUS, the chart below 

demonstrates how currently, global capacity is 35 million units with current production at 31 

million units. Driven primarily by ATG facilities, China currently produces 21.2 million units 

and is at 87% capacity. Those numbers dwarf the non-Chinese production. In fact, even if the 
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Office of the United States Trade Representative

October 9, 2018

Page 16 of 19

non-Chinese producers were working at 100% capacity, the production numbers would fall far 

short of satisfying the U.S. consumer demand. 

Looking next at all tools contained in tool holder sets classified in subheading

8466.10.0175, HTSUS, China again dominates production with 214.5 million units, working at 

87% capacity, driven primarily by ATG-owned facilities. The non-Chinese manufacturers lag 

far behind in both production and capacity:
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Office of the United States Trade Representative

October 9, 2018

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Office of the United States Trade Representative

October 9, 2018

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Furthermore, ATG’s own capacity could not be ramped up quickly enough to cover 

customer demand. Without our facilities in China, we will not be able to provide the highquality products to our customers at the prices they can afford. Ironically, our foreign

competitors that can avoid the 25% tariff will likely benefit from ATG’s loss of market share.

VII. Exclusion Proposal

As established above, the tool sets at issue are not high-tech products that are 

strategically important to or related to the “Made in 2025” or any other Chinese industrial 

programs. Moreover, China has never sought our technology for these items. Furthermore, they 

are not commercially available outside of China in quantities sufficient to meet consumer 
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Office of the United States Trade Representative

October 9, 2018

Page 19 of 19

demand and the imposition of an additional 25% tariff will cause serious economic harm to 

ATG, its retail customers, and American consumers. For these reasons, ATG respectfully 

requests that the tool sets described below be excluded from Annex A:

 “Hand Tool Sets Containing Ratchet(s), Sockets, and Bits (whether or not also including 

adapters and extensions (classified in 8466.10.0175).”

CBP’s enforcement of this exclusion request is very simple not only from a quick visual 

examination of the imported merchandise but from a review of import paperwork, for which the 

invoices will always describe the imported sets with an additional reference to this 10-digit 

classification number: 8466.10.0175, HTSUS. 

VIII. Conclusion

Based upon the foregoing, ATG respectfully request that the subject tool sets be excluded 

from Annex A, which is the final list of items subject to the additional 25% tariffs if imported 

from China.

Very truly yours, 

Thomas Pifer 

Director, Global Customs Compliance 

Apex Tool Group, LLC 

14600 York Road, Suite A 

Sparks, MD 21152 

Thomas.Pifer@apextoolgroup.com