Royal Consumer Information Products, Inc. 

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. 

Public Document 

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

The specific product included in this request is a 110 lb. shipping scale having a weighing capacity of 

1 101b / 50kgs with a remote display made with a platform material of stainless steel, having a power 

supply of AAA batteries with a size of 8" x 7" x 1.3.

5" and having a weight of 2 lbs. without packaging. 

Also included in this request a 330 lbs shipping scale having a weighing capacity of 330 lbs 149 kgs 

with a remote display made with a platform material of stainless steel, having a power supply of AAA 

batteries with a size of I I" x I I" x 3.5" and having a weight of 7 lbs 8 oz. with packagi 

3. 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/ 

8423820010 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

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

Requestor Representative: Beth C. Ring, Sandler, Travis & Rosenberg, P.A. 

5. Requestor's relationship to the product: Importer 

6. Does this submission in regulations.govinclude additional attachments? 

YES 

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. 

Public Document 

VERSION 1 CONTINUED BELOW 1 
8. Is this product, or a comparable product, available from sources in the United States?: 

NO 

9. Is this product, or a comparable product, available from sources in third countries?: 

NO 

1 0. 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: see attached 2017 Quantity: see attached 

2016 Value: see attached 2016 Quantity: see attached 

2015 Value: see attached 2015 Quantity: see attached. 

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). 

SEE ATTACHED 

VERSION 1 END 2 
SANDLER, TRAVIS & ROSENBERG, P.A. 

Customs & International Trade Law 

BETH C. RING 

SENIOR MEMBER 

DIRECT N0.: (212) 549-0133 

FAx: (212) 883-0068 

EMAIL: bring©strtrade.com 

October 4, 2018 

FILED VIA REGULATIONS.GOV 

Honorable Robert E. Lighthizer 

United States Trade Representative 

600 17thStreet Northwest 

Washington, D.C. 20508 

Subject: Docket No. 2018-00025 

Request for Exclusion of Weighing Scales Classified in HTSUS Subheading 

8423.82.0010 from the Determination of Action Pursuant to Section 301: China's Acts, 

Policies and Practices Related to technology Transfer, Intellectual Property, and 

Innovation 

Dear Mr. Lighthizer: 

On behalf of our client, Royal Consumer Information Products, Inc. ("Royal") we hereby 

request an exclusion from the decision to impose an additional 25 percent tariff on certain weighing 

scales imported from China as described below. Royal is a leading supplier of office products, 

accessories and supplies for the consumer and small business markets. With its roots in the Royal 

Typewriter Company, founded in 1904, Royal's product line has evolved to include cash registers, 

shredders, PDAs/electronic organizers, postal scales, weather stations, and a wide range of imaging 

supplies supporting today's most popular printers, faxes, and copiers. Royal Consumer Information 

Products headquarters is located in Bridgewater, New Jersey, where it has 23 employees. It also has a 

warehouse in Easton, PA with approximately 5 permanent and some additional temporary workers, 

551 Fifth Avenue, Suite 1100, New York NY 10176 USA • www.strtrade.com• 212.883.1300 

CHICAGO • HONG KONG • MIAMI . NEW YORK • SAN FRANCISCO • WASHINGTON, D.C. 
SANDLER, TRAVIS & ROSENBERG, P.A. 

Hon. Robert Lighthizer 

United States Trade Representative 

October 4, 2018 

Page 2 

and a third-party distribution center in Forest View, Illinois with 30 employees. 

The subject of this request is Royal DG110/and DG330 shipping scales capable of weighing 

up to 110 lbs. and 330 lbs. respectively and classified under HTSUS subheading 8423.82.0010 "Other 

weighing machinery: Having a maximum weighing capacity exceeding 30 kg but not exceeding 5,000 

kg: Digital electronic type." Royal's DG330 shipping scale was selected by the U.S. Postal Service 

after an exhausting product evaluation to be used at all United States Post offices. The DG110 scale is 

sold to Sam's Club for consumer use. 

These shipping scales should not be subject to the tariff increase because doing so does not 

serve the purpose of the USTR's investigation. These additional tariffs are harming Royal's business 

without providing any corresponding benefit to U.S. manufacturers or workers. These shipping scales 

are not manufactured in the United States, nor are U.S. components used to manufacture these scales in 

China. 

Royal has been manufacturing these scales at a single privately-owned Chinese factory for the 

past seven years. Royal's demand for these scales is approximately 25,000 units per quarter. Royal 

imported the following quantity and value of shipping scales in the past three years: 

Year Quantity Value 

2015 27,723 S276,370 

2016 20,822 S171,658 

2017 23,900 S473,404 

2018 (YTD) 47,160 S494,458 

If Royal is not ganted a one-year exemption from the 301 China tariffs, Royal would need to find a 

currently unknown manufacturer in another country where the prices are likely to be much higher and 

would not be acceptable to Royal's customers, the U.S. Postal Service and Sam's Club. 
SANDLER, TRAVIS & ROSENBERG, P.A. 

Hon. Robert Lighthizer 

United States Trade Representative 

October 4, 2018 

Page 3 

If. Sam's Club and the United States Postal Service are unable to absorb these additional costs, 

Royal will lose this revenue, which will impact the company's investment, hiring and growth. The 

financial losses incurred by the U.S. Postal Service have been specifically targeted by President Trump 

in a call for a commission to examine overhauling the agency to make it more profitable. See 

haps://www.govexec.com/management/2018/08/trumns-posta1-task-force-has-recomrnendationsready-president/150374/. Therefore, imposing an additional 25 percent tariff on these shipping scales 

directly contradicts this policy. Royal's retail customer has advised that the increased tariffs are 

directly impacting sales, as office products are not deemed a necessity. In fact, Royal's entire business 

model is being jeopardized since they are known as a manufacturer of office products, which are all 

now subject to these additional tariffs (the rest of their products are on the third list of duty increases 

effective September 23, 2018). 

Moreover, there is no proprietary or innovative technology involved in the manufacture of 

these scales, nor are they part of China's "Made in China 2025" effort. Since there is no U.S. 

intellectual property involved with the manufacture of these shipping scales, there is no technology 

transfer for the Chinese government to force. 

Product Description 

The specific product included in this request is a 110 lb. shipping scale having a weighing 

capacity of 110Ib / 50kgs with a remote display made with a platform material of stainless steel, having 

a power supply of AAA batteries with a size of 8" x 7" x 1.35" and having a weight of 2 lbs. without 

packaging. Because the weighing capacity is up to 110 lbs. this is classified under HTSUS subheadng 

8423.82.0010. 
SANDLER, TRAVIS & ROSENBERG, P.A. 

Hon. Robert Lighthizer 

United States Trade Representative 

October 4, 2018 

Page 4 

bmstatamist 

Also included in this request a 330 lbs. shipping scale having a weighing capacity of 330 lbs. 

149 kgs with a remote display made with a platform material of stainless steel, having a power supply 

of AAA batteries with a size of 11" x 11" x 3.5" and having a weight of 7 lbs. 8 oz. with packaging. 

Because the weighing capacity is up to 330 lbs. this product is also classified under HTSUS 

subheading 8423.82.0010. Because of the specific description of these items in the tariff schedule, and 

the statistical breakout of "digital electronic type," U.S. Customs and Border Protection would have 

the ability to administer the exclusion of these items, as the entire provision is: 

8423 Weighing machinery (excluding balances of a sensitivity of 5cg or better), 

including weight-operated counting or checking machines; weighing machine 

weights of all kinds; parts of weighing machinery: 

8423.82.00 Having a maximum weighing capacity exceeding 30kgs but not 

exceeding 5000kg 

8423.82.0010 Digital electronic type 
SANDLER, TRAVIS & ROSENBERG, P.A. 

Hon. Robert Lighthizer 

United States Trade Representative 

October 4, 2018 

Page 5 

Conclusion 

For all the foregoing reasons, we request that an exclusion from the 301 tariffs for 

100,000 weighing scales classified under HTSUS subheading 8423.82.0010 be granted to Royal. 

Sincerely, 

SANDLER, TRAVIS & ROSENBERG, P.A. 

By: 

Beth C. Ring