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 I 

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

This exclusion request is for product number SWE4357, a projection welding machine made of primarily 

steel and used in the automotive sector in the manufacture of automotive components. The dimensions 

are 800xl500xl600mm and it weighs 1.5 tons (480V l l0kVA). The product is shipped in a wooden 

crate with the product's part name- "Asset # SWE4357" clearly indicated with accompanying 

documents. This distinguishes this product from other imported products and facilitates the 

administration of this exclusion by CBP. 

3. IO-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/ 

8515800080 

4. Requestor Information 

Requestor Name (Last, First): !Koursova, Larissa 

:::::===:::::::::==================================:::::: Organization Name: !Aisin World Corp. of America 

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

Requestor Representative: !David Hamill, PARTNER, Arent Fox LLP 

5. Requestor's relationship to the product: ... IP_ur_c_h_a_s_er _________________ __. 

6. Does this submission in regulations.gov include additional attachments? 

IYES 

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

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

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: * 

20 17 Quantity: * 

2016 Quantity: * 

2015 Quantity: * 

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). 

* This is a new product that has not historically been imported, but will be imported in the 

upcoming months due to previously planned production 

See attached for arguments in support of this exclusion request. 

VERSION 1 END 2 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551  Fax: (734) 453-4670

October 9, 2018

VIA REGULATIONS.GOV PUBLIC DOCUMENT

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516

Washington, D.C., 20006 

Re: Request for Exclusion of Projection Welding Machine HTS 8515800080 from the Determination of 

Action Pursuant to Section 301 Tariffs

Dear Ambassador Lighthizer:

Aisin U.S.A. Mfg., Inc (AUM) respectfully submits this request for exclusion of Projection Welding 

Machine from the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1

AUM has purchased and is in the process of purchasing the following parts of a Projection Welding 

Machine through 2018 and first half of 2019:SWE4340, SWE4343, SWE4341, SWE4344, SWE4342, 

SWE4345, SWE4355, SWE4356 and SWE4357

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

World Corp. of America headquarters are in Northville Michigan. In addition, our research and development 

capabilities can be found throughout the United States. 

 1 19 U.S.C. § 2411. 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551  Fax: (734) 453-4670

AISIN AUM is located in Seymour, IN where over 1,000 employees are committed in producing high 

quality, functional, engine components for some of the largest automotive manufacturers in the United States.

Our approach has always been to follow a global strategy and establish our family of companies in the 

U.S.to support the U.S. domestic and U.S. import manufacturer base. We are constantly striving toward product 

improvement that will benefit consumers and its emphasis on environmental sustainability, community 

involvement and employee life balance, Aisin consistently lives up to its motto: “For a Better Tomorrow.”

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid to long range, our 

strategy in the United States is to squarely focus on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customers. For AISIN AUM, this is an investment for the future we gladly make. 

This exclusion request addresses a projection welding machine classified under HTSUS subheading 

8515.8000.80 which are currently subject to the 25% additional Section 301 tariff. AISIN AUM utilizes these 

welding machines to produce door frames, seats, sunroofs assemblies for our US based customers. The welding 

machine we cite in this 301 exclusion request is purchased from China because it meets our product 

requirements.

In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2 AISIN AUM provides the following information requested by the USTR in support of this request. 

 2 Procedures To Consider Requests for Exclusion of Particular Products From the Determination of Action 

Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual 

Property, and Innovation, 83 Fed. Reg. 32,181 (USTR July 11, 2018).
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551  Fax: (734) 453-4670

1. Availability of the product outside of China

AISIN AACT invested a considerable amount of time and capital in working with our Chinese partner to 

ensure that these products were manufactured to our design requirements specifications. While an effort to find 

another manufacturer that would be able to produce this machine to our customers’ specifications is possible, it 

would take at least 9 months to resource, which would include approximately 3 months to build a new casting 

dies and another 6 months to validate and test the machine.

For an automobile, the quality and consistency of materials, components, and machine are of the utmost 

importance because they can impact the vehicles quality, safety, and performance. This is especially true for 

safety sensitive components such as doorframes and automotive seats. 

In short, this product from China has met the final approval of our automotive customer in the United 

States. The process to validate a new country source will require extensive testing to validate the product, both 

for our purposes as well as our OEM customers. More importantly, there is significant risk involved with the 

quality and delivery aspects of this revalidation in terms of production schedules. 

2. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requester or other US interests

The projection welding machine purchased by AISIN AUM. that are included on the USTR’s product 

list is a key component of our automotive parts manufacturing and are imported to support domestic 

manufacturing operations and American jobs in the United States. The imposition of a 25% tariff on the 

welding machines would cause severe economic harm to U.S. interests, including our employees, our customers, 

and consumers, who eventually will be paying higher prices for new vehicles. Specifically, any future business 

opportunities involving these products could be directly impacted by the price increase caused by the additional 

tariff. Our concern here is that the 25% tariff will impact the company’s production costs, reducing profit 

margins and therefore minimizing any future R&D investments, in the long-run negatively impacting Aisin 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551  Fax: (734) 453-4670

production strategy in the US. This will, in turn, adversely affect a broader spectrum of U.S. interests, including 

U.S. investments, and jobs. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or other 

Chinese industrial programs

The imposition of a 25% ad valorem duty on this projection welding machine from China will not 

impact the Chinese intellectual property violations these seek to eliminate. Section 301 tariffs are aimed at 

specifically targeted products that have benefitted from the China’s acts, policies, and practices detailed in the 

USTR’s Section 301 Report. Made in China 2025 aims to promote their indigenous research and development 

capabilities. The welding machine is not a new technology. 

We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted,

Larissa V. Koursova

Assistant General Manager, Purchasing

Aisin World Corp. of America

Phone +1 734 582 7654

Mobile +1 248 756 9958

lkoursova@aisinworld.com