Public Document

This exclusion request is for product number Part #KDA3904. The dimensions are: W=2107 mm, H= 

1341 mm, and T=900mm. This product is a Die Casting Die (3) for Product # 946F TCC #1. It is made 

of FCD500 and SKD61. It’s weight is 6800 Kg and it is used in the manufacture of an automotive 

engine. It is shipped one unit per wooden crate and the product number is clearly indicated on each die to 

facilitate the administration of the 301 tariffs by CBP. 

8480490000

Koursova, Larissa

Aisin World Corp. of America

David Hamill, PARTNER, Arent Fox LLP

Purchaser

YES

Public Document

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. 

I. Indicate whether the comment contains business confidential information (BCI), is a public 

document, or is a public version of a BCI document. 

I I 

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

3. I 0-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/ 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

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

Requestor Representative: 

5. Requestor's relationship to the product: 

6. Does this submission in regulations.gov include 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. 

VERSION 1 CONTINUED BELOW 1 
NO

NO

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* 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.

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. 

2017Value: 

2016 Value: 

2015 Value: 

2017 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). 

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

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

October 8, 2018 

VIA REGULATIONS.GOV PUBLIC 

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 Die Casting Die from the Determination of Action Pursuant to Section 301 

Tariffs

Dear Ambassador Lighthizer: 

Aisin AACT respectfully submits this request for exclusion of die casting die from the proposed 

determination of action pursuant to Section 301 of the Trade Act of 1974.1

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. 

AISIN AACT is located in Clinton TN and is one of the largest manufacturing employers in the area. 

Here over 550 employees are committed in producing high quality, functional, engine components for some of 

the largest automotive manufacturers in the United States. 

1

 19 U.S.C. § 2411. 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

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

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 AACT, this is an investment for the future we gladly make. 

This exclusion request addresses die casting die classified under HTSUS subheading 8480.49.0000 

which are currently subject to the 25% additional Section 301 tariff. AISIN AACT utilizes these dies to produce 

a timing chain cover used by our OEM customer for engine assembly. The dies we cite in this 301 exclusion 

request is purchased from China because it meets our engineering requirements. 

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

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

1. Availability of the product outside of China 

In this particular case, we might have the ability to source dies from other countries. However, our U.S. 

customer specifications are exact and rigorous. 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 

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). 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

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

requirements specifications. While an effort to find another manufacturer that would be able to produce this 

equipment 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 

equipment. 

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

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

engine components that are produced from the die casting die subject to this exclusion request. 

In short, this product from China has met our final approval and that 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 die casting die purchased by AISIN AACT 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 die casting die 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 production strategy. This will, in 

turn, adversely affect a broader spectrum of U.S. interests, including U.S. investments, and jobs. 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

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

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 AISIN AACT’s die casting die 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 die casting die is not a new technology or made with breakthrough “new” material. 

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 

AISIN • 

A/SIN GROUP