TriMas 

October 3, 2018 

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

600 17thStreet, NW 

Washington, DC 20508 

RE: Docket number USTR-2018-0025, Section 301 

Dear Ambassador Lighthizer: 

TriMas Corporation ("TriMas" or "we) respectfully submit the following request to exclude 

guards and housings for flywheels for engines, classified under 8483.90.8080, from the tariffs 

enacted against products from China pursuant to Section 301 of the Trade Act of 1974. These 

products have been subject to an additional 25% duty since July 6, 2018. 

TriMas is a diversified manufacturer of engineered products that serve a variety of industrial, 

commercial and consumer end markets worldwide. Our family of businesses provide customers 

with innovative product solutions under well-recognized brands and have leadership positions in 

the niche markets they serve. Our businesses provide manufacturing jobs in the U.S. and have 

established relationships with suppliers and customers globally. The businesses import both 

components for further manufacturing and assembly in the U.S., as well as finished goods. TriMas 

employs more than 2,100 employees in the U.S. and our global headquarters is in Bloomfield 

Hills, Michigan. 

These tariffs negatively affect our businesses within the U.S. This exclusion request specifically 

addresses the flywheel guards and housings imported by our business Arrow Engine Company 

("Arrow"). 

Background 

Arrow is a market-leading provider of natural gas-powered engines and parts, as well as gas 

compressors, gas production equipment, meter runs, engine electronics and chemical pumps to a 

variety of industrial, commercial and consumer end markets worldwide. Arrow's headquarters is in 

Tulsa, Oklahoma and provides approximately 100 U.S. jobs, with approximately 70 of those jobs 

dedicated to manufacturing. 

The Section 301 tariffs that were implemented on July 6thhave impacted the flywheel guards and 

housings Arrow imports from China under HTS 8483.90.8080, which provides for parts of 

flywheels (among other goods as well). These goods are described as "Housing FlywheeP, 

"Flywheel Housing", and Flywheel Guard" on the invoices Arrow receives from its suppliers. 

38505 Woodward Avenue, Suite 200, Bloomfield Hills, Michigan 48304 P 248-631-5497 F: 888-318-8873 E: joshsherbin@trimascorp.com 
The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 3, 2018 

Page 2 of 3 

These guards and housings provide an integral enclosure for the flywheels. These goods are 

castings and are made of iron or aluminum. The dimensions for these goods range from 24" x 24" 

to 4 x 4, with weights from 25 lbs. to 450 lbs. A flywheel is a mechanical device specifically 

designed to efficiently store rotational energy. Flywheels resist changes in rotational speed by their 

moment of inertia. 

These guards and housings are assembled on to the flywheels that are assembled onto engines that 

are used by the oil and gas industry. Arrow imports these guards and housings to sell directly as 

pass-through finished goods, as well as to install and assemble on flywheels on customized engines 

in Tulsa prior to sale. 

Availability of Quality Product 

Arrow started sourcing from China in order to remain competitive in the market. Although other 

suppliers exist for this product in different countries, qualifying a new supplier to produce this 

good could take several years. Starting a new line would be extremely capital intensive due to the 

costs for tooling, fixtures and dies. The goods must also meet varied requirements of ASTM and 

ISO. 

Tariffs Cause Economic Harm to Arrow and U.S. interests 

Arrow has been directly impacted by the Section 301 tariffs that went into effect on July 6th, 

August 23, and September 24ththis year, as well as indirectly by the Section 232 steel tariffs 

implemented earlier this year. Higher tariffs increase Arrow's costs, and impact profit margins, 

which could negatively impact wages and headcounts at the company. 

The increased cost for the flywheel guards and housings negatively affects Arrow's ability to sell 

competitively in the U.S. and globally. Foreign suppliers of these products will have a global 

competitive advantage over Arrow, due to not having to pay the additional costs of the Section 232 

and 301 tariffs. The increased cost for these goods is also being passed on to U.S. customers. 

If a customer decided to prolong routine maintenance on the engines due to increased costs, the 

likelihood of engine failure and poor perfounance would increase. Downtime on oil and gas wells 

due to engine failure can cost up to $25K per day to a producer. 

Flywheel Guards and Housings Not Related to "Made in China 2025" Initiative 

All R&D for its products is done in-house at Arrow in Tulsa, and intellectual property is protected 

through agreements Arrow has with its suppliers. The suppliers Arrow sources from are primarily 

privately-owned companies in China. The privately-owned suppliers Arrow works with have not 

required technology transfers or data localization requirements. TriMas' terms and conditions in 
Sincere 

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 3, 2018 

Page 3 of 3 

our purchase orders, used by Arrow, require suppliers to agree to the ownership and protection of 

technical information provided. 

These flywheel guards and housings do not relate to advanced technology, advanced design or 

manufacturing technology, and are not part of the priority industries or related to "Made in China 

2025" or other Chinese industrial programs. The goods are not referenced in the Section 301 

report from the USTR (Findings of the Investigation into China's Acts, Policies, and Practices 

Related to Technology Transfer, Intellectual Property, and Innovation under Section 301 of the 

Trade Act of 1974). Subjecting these guards and housings to additional duties is not effective in 

eliminating China's acts, policies, and practices, but instead negatively impacts businesses in the 

U.S. by raising the prices of these goods and the finished good engines. 

Conclusion 

We have outlined our reasons why we believe the flywheel guards and housings classified under 

8483.90.8080 should be excluded from Section 301 tariffs. In summary, the goods should be 

excluded for the following reasons: 

1) the goods are not produced cost-effectively in the United States nor in any other country besides 

China at volumes or quality required by the market; 

2) these tariffs cause disproportionate economic harm to our businesses and also down-stream to 

our U.S. customers and to U.S. consumers; and 

3) the goods are not part of the priority industries or related to "Made in China 2025" or other 

Chinese industrial programs. 

The information provided in this exclusion request is complete and correct to the best of our 

knowledge. We request certain quantity and value information contained in the BCI exclusion 

form be afforded business confidential treatment. The disclosure of such information would 

endanger trade secrets or profitability, and the information would not customarily be released to 

the public. However, this letter does not contain confidential information, and can be released as a 

public document. 

We respectfully request the exclusion of flywheel guards and housings from the additional duties 

under Section 301. Thank you for your consideration. 

Josh erbin 

Gener ounsel and Chief Compliance Officer 

TriMas Corporation 

38505 Woodward Avenue, Suite 200, Bloomfield Hills, Michigan 48304 P 248-631-5497 F: 888-318-8873 E joshsherbin@trimascorp.com