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).
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October 9, 2018 

By Electronic Filing via www.regulations.gov

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, N.W. 

Washington, DC 20508 

Attn: Mr. Arthur Tsao 

Assistant General Counsel, U.S. Trade Representative 

Re: Docket No. USTR-2018-0025 

Request for Exclusion of Products Classified under HTS No. 8432.80.0080

Dear Ambassador Lighthizer: 

Camco Manufacturing, Inc. (“Camco”), headquartered in Greensboro, North Carolina, and with 

facilities in Indiana and Oregon, respectfully requests an exclusion from the Section 301 China 

tariffs for its Black Boar ATV Landscape Rake Implement products classified under Harmonized 

Tariff System (“HTS”) subheading 8432.80.0080. As this supporting letter details, Camco has 

no immediate viable options than to continue to import the products more fully described herein 

from China, and the tariff implemented by the U.S. Trade Representative (“USTR”) will have a 

significantly harmful impact on the company’s operations and business plans. Camco believes 

that approving this exclusion request will not impede the U.S. government’s efforts to address 

China's unfair trade practices. 

Camco certifies that the information contained within brackets (“[ ___ ]”) in this exclusion 

request contains business confidential information, that disclosure of this information would 

endanger company trade secrets or profitability, and that this information would not customarily 

be released by Camco to the public. Such information is exempt from disclosure under the 

Freedom of Information Act, 5 U.S.C. § 552. A public version of this submission with 

redactions has been prepared and submitted to the docket in this matter for public review. 

I. Background

Camco began business in 1966 with one employee and one product and has grown into a proud 

American company with now 467 U.S. employees and over 3,000 products. By working with 

inventors, entrepreneurs and small businesses, Camco has been able to bring and keep products 

in the U.S. market. In 2005 and 2010, Camco opened two manufacturing facilities in Beilun, 

China and Changxing, China. These two Chinese companies, Ningbo Healthy East Plastics and 

Metals and Changxing Dekai Vehicle Accessories Co. are wholly foreign-owned enterprise 

(“WFOE”) owned solely by Camco with no Chinese joint venture partners or ownership. 
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In these wholly owned China factories, Camco manufactures our own products with our own 

proprietary technology and trade secrets. These products are then imported into the United 

States as finished products and sold via multiple RV, camping, marine, hardware or other 

outdoor-related stores across the country. 

II. Product Description 

All-terrain vehicle (ATV) Landscape Rake, Implement. The Camco Black Boar ATV Landscape 

Rake Implement is a product that is designed for clearing trails and raking debris. The rake has 

twenty (20) individual tines; each is removable to adjust the coarseness of the rake. It is made of 

powder coated steel, measures 30 x 17 x 4 inches, and weighs approximately 48 pounds.. This 

ATV landscape rake is imported from our wholly-owned China factories as a finished product 

under HTS subheading 8432.80.0080. 

A. U.S. Customs and Border Protection (CBP) Ability to Administer the Exclusion 

These Camco Black Boar – ATV Landscape Rake, Implements are shipped from China via 

ocean freight from various ports in China ( [ Shanghai, Beilun ] ). They are imported into the 

United States as finished product classified under HTS subheading 8432.80.0080. Given that 

they are already Camco products, the commercial invoice and shipping documentation includes 

the Camco part number (#66002), a product description including the use of the term “landscape 

rake”. 

Camco’s exclusion request will not add any undue burden on CBP’s current entry review and 

procedures for imports. CBP will be able to readily identify these products to apply the 

exclusion. 
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III. Rationale for the Requested Exclusion 

For the following reasons, Camco believes that the USTR should consider and grant this product 

exclusion request: 

A. Camco is Unable to Source Production from the United States or Third Countries 

Camco is extremely limited in its options to obtain this product from sources in the United States 

or in other third countries. 

i. Production in Third Countries 

As noted above, Camco fully owns and operates the two Chinese facilities where this product is 

manufactured. These facilities are operated as WFOEs, a unique investment vehicle in China 

that provides Camco with full control over the business and its operations. There is no 

government or state-owned enterprise investment. In these China facilities, Camco directly 

manufactures the product covered under this exclusion request with our own proprietary 

technology and valuable trade secrets, and we conduct stringent quality control inspections and 

testing. This ownership and control has ensured that Camco can protect our intellectual property; 

there have never been any instances or issues involving the forced transfer of technology to 

which the additional Section 301 tariffs seek to remedy. 

There are no other viable options for production of this product in other countries. There are no 

other qualified manufactures of this type of product that are not direct competitors of Camco. 

Therefore, if the company sourced the manufacturing of this product elsewhere, it would have to 

be to our direct competitors. This would place our patents, trade secrets, intellectual property 

and manufacturing know-how into the hands of our competitors and, thus, undermine Camco’s 

position in the U.S. and global markets. Camco already expends a significant amount of funds to 

protect its intellectual property from infringement and has been highly successful in doing so. 

Providing our proprietary intellectual property to other sources would assist our competitors in 

developing similar products to unfairly compete with Camco. 

ii. Production in the United States 

Even if Camco shifted production to our U.S. manufacturing facilities, there would be two 

immediate and negative financial impacts. First, moving production to the United States for this 

product would require significant time and expense in either revamping current facilities or 

leasing and renovating manufacturing space in order to start a new production line for this 

product. Further, it would take one to two years to move production and train employees on the 

manufacturing process for this product that has been manufactured in our own China facilities. 

However, if production was shifted to the United States, Camco would likely still not be able to 

fully produce the necessary quantity of this product in our existing U.S. facilities to meet current 

consumer demand, and certainly could not do so in a more efficient manner than is currently 

being done in our China facilities. Increased costs for raw materials, labor costs and associated 
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overhead expenses in the United States would have a significant and negative impact on 

Camco’s balance sheet. Camco’s two wholly-owned Chinese facilities produce high-quality 

products in an efficient and cost-effective manner that support and complement our current U.S. 

operations. 

Second, as noted, Camco currently operates two WFOE facilities in China that are fully 

operational. Camco invested approximately [ $3.0 million ] in these facilities and ceasing 

production and moving the affected items quickly from China due to the tariffs would 

immediately [ drive these two factories into a loss position. There would not be sufficient time to 

phase down production without taking huge financial losses ]. Overall, Camco could not [ 

maintain profitability if these foreign factories were idled and/or closed ]. 

B. Severe Economic Harm Caused by Imposition of the Tariffs 

The imposition of a 25% tariff on this product under HTS subheading 8432.80.0080 is causing, 

and will continue to cause, severe economic harm to Camco and other U.S. interests, including 

our network of over 600 authorized dealers and retailers in the United States, and our ultimate 

end-user customers. 

The increased cost of the tariffs significantly harms Camco’s revenues, costs, profitability, 

employee outlook, capital investment and other prospects. These consequences may also 

directly affect Camco’s ability to continue providing state-of-the-art RV, camping, marine 

products to customers in the United States, to continue to fund research and product development 

activities, to consider new product lines, and would adversely impact our competitive position in 

the marketplace.

The resulting increased costs of importing our own product from China will lead to a greater 

increase in the price to the our dealers and other authorized retailers, which will lead to an even 

greater increase in the price to the ultimate U.S. consumer. 

C. Product is Not of Strategic Importance to the “Made in China 2025” Program 

Camco’s product as described herein is manufactured in China in Camco’s wholly-owned 

facilities and are not strategically important or related to any “Made in China 2025” or other 

industrial programs in China. The products are accessories for use in outdoor camping and 

marine environments, including uses on RVs, ATVs and boats. Furthermore, given that Camco 

owns the intellectual property and trade secrets, and the fact that the product is manufactured in 

our own facilities, manufacturing of these products in China does not involve any transfer of 

intellectual property to any Chinese entities or governmental authorities and has never involved 

any forced technology transfers. As such, it is not likely that imposition of the Section 301 tariff 

on this product will force China to curb any discriminatory acts or policies. 

The principal consequence of the Section 301 tariff on Camco for importing this product is to 

impose a 25% additional cost on our U.S.-based operations that is severely disadvantageous to 

the company and, ultimately, to our U.S. customers. 
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IV. Conclusion 

Given the above, Camco respectfully seeks approval of this exclusion request. Camco owns and 

controls the two Chinese facilities where the product that is the subject of this request are 

produced; thus, there are no other viable options for production outside of China. The involved 

products are not high-tech in nature and would not benefit the “Made in China 2025” program, 

and the imposed tariff on these products will not advance the USTR’s goal of seeking a change 

to China’s unfair trade practices. Instead, the imposition of this additional 25 percent tariff on 

this product will mainly affect and undermine Camco’s operations and our competitive position 

in both the U.S. and global markets. 

Sincerely, 

Donald Booth 

Vice President – Global Procurement 

Camco Manufacturing, Inc. 

121 Landmark Drive 

Greensboro, NC 27409