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 particular product of concern:

4.

*

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/

7.

5. Requestor's relationship to the product:

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.

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1
8. Is this product, or a comparable product, available from sources in the United States? (If you

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

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:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).
Exhibit A
NOT SUSCEPTIBLE TO 

PUBLIC SUMMARY
October 5, 2018

Ambassador Robert E. Lighthizer 

U.S. Trade Representative 

600 17th St. NW

Washington, DC 20006

PUBLIC VERSION

Re: Section 301 Product Exclusions, USTR-2018-0025-0001 – Valmet, Inc. Request for 

Exclusion of Parts of Papermaking Machinery and Related Products 

Dear Ambassador Lighthizer: 

Valmet, Inc., a Delaware corporation (“Valmet USA”) appreciates the opportunity to 

request exclusions from the 25 percent tariffs imposed on several Chinese-origin imports in 

connection with the investigation of certain Chinese acts, policies, and practices (“APPs”) under 

Section 301 of the Trade Act of 1974 (“Section 301”). In particular, Valmet USA seeks to 

exclude several custom-designed components of our papermaking machinery products classified 

under the following codes of the Harmonized Tariff Schedule of the United States (“HTSUS”): 

7308.90.9590, 8419.90.2000, 8421.99.0080, 8439.91.9000, 8439.99.1000, 8439.99.5000, and 

8483.40.9000. These consist of low-tech components, which are incorporated with our high-tech 

components produced in Finland, Sweden and Canada to produce very large papermaking 

machines – the size of more than the length of a football field and four stories tall. We are 

seeking exclusions for equipment that will be delivered over the next year under contracts that 

were all negotiated and signed prior to President Trump’s announcement regarding potential 

tariffs on March 23, 2018. 

As stated in our comments and at the hearing for the tariff proceedings in connection with 

Lists 1 and 2, Valmet Corporation (the ultimate parent company of Valmet USA), including its 

affiliated legal entities (collectively, “Valmet” and “we”), is the leading global developer and 

supplier of technologies, automation and services for the pulp, paper and energy industries. 

Valmet's technology offerings include pulp mills, tissue, board and paper production lines, as 

well as power plants for bioenergy production. Our product offerings also include services and 

automation solutions. In terms of market share, Valmet’s market position varies from between

number one to three globally in all the sectors in which we operate. Valmet Corporation is a 

publicly traded company headquartered in Finland and has U.S. locations in a number of states, 

including Alabama, Georgia, Maine, Mississippi, North Carolina, Pennsylvania, South Carolina, 

Washington, and Wisconsin which U.S. locations operate through the legal entity Valmet USA. 

Valmet USA supplies its U.S. customers, with papermaking machinery and products and energy