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 particular product of concern: 

Item Name: Two Station Screw Capping Machine 

Dimensions/Weight: 1000mm x 900mm x 1800mm; 300 Kgs 

Power Source: 220v 

Material Composition: Stainless steel 

Use/Capabilities: The Two Station Screw Capping Machine is a versatile, in-line capper that can handle 

the wide range of containers LSI utilizes. It caps up to 100 Bottles Per Minute, does not require tool 

changeover, and has a chute adjustable to different sized caps. 

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/ 

8422309140 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Benson, Richard 

Lubrication Specialties, Inc. 

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

Requestor Representative: Benson, Richard 

5. Requestor's relationship to the product: Purchaser 

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

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. 

N/A 

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

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

fro EJ 

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

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

NO 

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: 0 2017 Quantity: 0 

2016 Value: 0 2016 Quantity: () 

2015 Value: 0 2015 QuantitY: 0 

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

the production of a final product or products? 

FINAL PRODUCT a 

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

0 % of your total gross sales in 2017 that the Chinese-origin product accounted for. 

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

% 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. 

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12. Please provide information in support your request, taking account of the 

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). 

The Two Station Screw Capping Machine herein described is part of a larger bottling line, imported into 

the U.S. in order to increase the number of manufacturing jobs available to American workers. As we 

will be using the machine with several different sizes and shapes of bottles, ranging from 16-64oz; 

6.5-10" in height, and 2-4.75" wide, and each part of the line must be properly synchronized with the 

others to achieve maximum efficiency, each of its parts had to be custom fit to the whole and designed 

for our bottles. 

Lubrication Specialties Inc., is a small business comitted to growing the local and American economies. 

When we made the purchase order for the Two Station Screw Capping Machine, as part of the purchase 

of an entire bottling line, there were no ready-made bottling lines fitting our needs available from a U.S. 

or third-country source. The line had to be custom built. 

By the time the tariff was imposed, production had alieady been substantially completed and only had to 

be shipped. Reneging on the deal would not only have harmed LSI's reputation, but would have 

damaged the United States reputation at home and abroad. Moreover, it would have cost American 

workers time on the job, as we would have had to wait approximately 6 months for a replacement 

bottling line to be manufactured in the U.S. 

As the tariff imposes significant economic harm on our small company, there are no immediately 

available replacements manufactured in America or a third country, and the Two Station Screw Capping 

Machine is not listed on the China 2025 list, and excluding the components of bottling lines from the 

tariffs will help bring manufacturing jobs back to America, we respectfully request the Two Station 

Screw Capping Machine be excluded from the tariff. 

The information provided is complete and correct to the best of my knowledge. 

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