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):

Public Document Other NON/A
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 *TUIJTQSPEVDU
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Barksdale is a manufacturer of controls for industrial applications specializing in the control and measurement of 

fl uids. Barksdale is also ISO/TS 16949:2009 certifi ed for the automotive industry. Barksdale is a subsidiary of Crane 

Co., Stamford, CT. Founded in 1949, Barksdale is based in Los Angeles, CA, and has manufacturing facilities in 

Reichelsheim, Germany and Suzhou, China.

To the request for public comment issued on April 6, 2018 (83 Fed. Reg. 14906), we want to outline the impact to 

the business and request an exclusion. Barksdale respectfully requests that HTS 8481.90.90 (Parts of taps, cocks, 

valves and similar appliances for pipes, boiler shells, tanks, vats) be removed from the proposed Section 301 tariff 

list 1.

1. The products provided from China suppliers are primarily for the pressure and temperature switches. These 

suppliers do not participate in “Made in China 2025". This doesn’t help achieve any broader benefi t from the 

Section 301 standpoint.

2. The parts imported from China for these switches have specifi c tooling designed for the machines used by 

the suppliers to manufacture these products. The specifi c machine/tooling used to manufacture such parts 

is currently only available in China. It will require signifi cant effort in terms of time and training to get another 

supplier to match the size and the technology to manufacture these parts. We estimate it can be months or 

years to do so.

3. From an Intellectual Property standpoint, Barksdale owns the part design but, our suppliers in China own the 

technology to make these parts. We will need to learn the technology on our own before we can onboard any 

domestic supplier to make these parts. Developing this technology knowledge will drive signifi cant costs into the 

business through research, resources and investments, with no assurance that we can reproduce the technology. 

Higher costs that must be passed on to the customer will negatively impact our competitive advantage.

4. Our customers will be affected through higher costs and disruption in supply to their production requirements. 

Barksdale, as well as many of our long standing customers have US manufacturing operations, thus creating 

jobs and investments domestically for many decades. The new tariffs may affect our ability to support our current 

workforce and future investments in the business domestically.

For these reasons we respectfully request the exclusion of the HTS code 84819090 from the list of proposed items 

under Section 301 Tariffs.

We sincerely appreciate your consideration of our request above.

$109,777 19,087

18,667

24,481

$107,743

$191,183