Polaris - Addendum for Snow Plow Parts Exclusion 

PUBLIC VERSION 

0PDLARIS$ 

I. Executive Summary 

Polaris Industries Inc. ("Polaris") is a stalwart U.S. manufacturing company that represents the 

U.S. paradigm of a strong American brand competing and winning in the global marketplace. 

Our vision is to fuel the passion of riders, workers and outdoor enthusiasts around the world by 

delivering innovative, high-quality vehicles, products, services, and experiences that enrich their 

lives. 

Our company has become synonymous with adventure and passion, in both work and play. For 

nearly 65 years, we have been making high-quality, breakthrough products- whether launching 

the snowmobile industry, reinventing A TV categories year after year, developing the first 

purpose-built ultra-light military vehicles, or introducing a radical 3-wheel mote-roadster. 

Polaris stands firmly behind the Administration's goal of freer and fairer global trade based on a 

rules-based system by which all countries must abide. We greatly appreciate the commitment of 

the President and his Administration to strengthening U.S. manufacturing and supporting 

American manufacturing jobs. We also support the Administration's goal of holding countries 

and competitors accountable to playing by the rules. Placing all industry on a level playing field 

allows capitalism to flourish, and we are confident Polaris will succeed in that environment. 

Polaris, however, respectfully requests that USTR mitigate the adverse impacts of the Section 

301 tariffs on Polaris' U.S. manufacturing operations. Mitigating those impacts will avoid the 

unintended consequence of providing foreign competitors, which manufacture outside the United 

States, a competitive advantage over Polaris and its U.S.-produced vehicles. 

USTR can minimize the potential harm to U.S. manufacturers like Polaris by (1) granting the 

product-specific exclusions requested in this and other submissions; and (2) expanding the 

1 
Polaris - Addendum for Snow Plow Parts Exclusion 

PUBLIC VERSION 

exclusion criteria available under the Section 301 process. [ 

] 

II. Specific Exclusion Request for Snow Plow Frames and Blades 

A. Additional Information about Intellectual Property and Made in China 2025 

Snow plow parts are not high technology products. Polaris has been using the same snow plow 

parts design and manufacturing methods, primarily developed in the United States, for five years. 

Snow plow parts are made primarily of steel. Snow plow parts are a low skill labor and mature 

technology, not at risk of forced technology transfer. These are not products implicated by 

China's "Made in China 2025" policies and are not subsidized by the Chinese government. 

2 
Polaris - Addendum for Snow Plow Parts Exclusion 

PUBLIC VERSION 

B. Draft CBP Language 

Polaris believes that CBP can easily exclude the snow plow parts in question based solely on the 

product description. The following are draft CBP exclusion instructions: 

Excluded from the Section 301 duties are steel frames and steel blades for snow plows. The 

frame connects to the blade on one side and connects to the mount on the undercarriage of a 

vehicle on the other side. The frame provides support for positioning of the blade when 

plowing. The frame is typically left connected to the blade and is used as a disconnection 

point from the body of vehicle. The blade is part of the snowplow system which scrapes 

surfaces being plowed and forces snow out of the path of a vehicle. 

This information will be contained on the invoice from the supplier listing the fact that the 

products are snow plow parts as described above. 

3 
Polaris - Addendum/ or Snow Plow Parts Exclusion 

PUBLIC VERSION 

III. Polaris Requests that USTR Mitigate the Adverse Impact of the Section 301 

Retaliatory Duties on U.S. Manufacturers 

A. Polaris is a Proud U.S. Manufacturer and Supports the Administration's 

Efforts to Create Free and Fair Trade 

Polaris is proud to be part of the storied history, and promising future, of U.S. manufacturing. 

We employ over 9,000 Americans, including 5,800 manufacturing workers, and willingly 

shoulder the responsibility of preserving their jobs and, through growth, creating even more. We 

pay competitive wages, [ ] 

and grant stock to our employees, making our employee stock ownership plan Polaris' fourth 

largest shareholder. 

Polaris exemplifies American manufacturing and pro-American sourcing. Polaris proudly 

manufactures vehicles and engines at six U.S. factories in Huntsville, Alabama; Anaheim, 

California; Elkhart, Indiana; Spirit Lake, Iowa; Roseau, Minnesota; and Osceola, Wisconsin. 

Polaris also buys from suppliers in the United States to make our vehicles and engines and sells 

Polaris vehicles to consumers through independent dealers throughout the United States. [ 

] We recently built the $190 million Huntsville plant and 

are currently constructing a $50 million distribution center in Fernley, Nevada. 

Polaris' history proves that manufacturing generates wealth, and we know that a strong 

production sector is the backbone of a flourishing economy. However, without free and fair 

trade, U.S. products find themselves at a disadvantage in a worldwide market rife with 

government subsidies and punitive tariffs. This Administration understands the necessity of fair 

trade. It is admirably working toward instituting modernized trade agreements that remove 

unfair barriers to free trade. Polaris steadfastly supports these policies, which will ultimately 

benefit U.S. workers and consumers, as well as their international counterparts. 

B. Polaris Is Affected by Section 301 Tariffs, But Some Foreign Competitors 

Are Not 

Current Section 301 tariffs have resulted in [ ] higher costs for many components and 

parts used for final assembly in Polaris' U.S. factories. These Section 301 impacts are in 

addition to the increased costs of materials and components resulting from the Section 232 

steel/aluminum tariffs and the EU's 25% retaliatory tariffs on our Spirit Lake, Iowa-produced 

motorcycles and Canada's 10% retaliatory tariffs on our Elkhart, Indiana-produced boats. 

The unfortunate irony is that Polaris - a U.S.-based manufacturer and powersports market leader 

- is substantially affected by the Section 301 tariffs, while foreign-based competitors -

manufacturing outside the United States - are not. [ 

4 
Polaris - Addendum for Snow Plow Parts Exclusion 

PUBLIC VERSION 

C. Immediate Relief Is Needed 

The cost to Polaris of the currently-imposed tariffs and retaliatory tariffs is [ 

] 

] [ 

] 

Given the [ ] to Polaris' business, not shared by some of our foreign 

competitors, Polaris respectfully requests that USTR grant relief as soon as possible. 

IV. Confidentiality Statement 

Consistent with USTR's Section 301 notice, Polaris requests confidential treatment for the 

information designated as business confidential in this submission. Such information consists of 

information that would not customarily be released to the public, including business or trade 

secrets regarding production costs and processes, data on sales, product characteristics, 

customers, destinations, and other product, sales, and cost-related business secrets. Business 

confidential information has been indicated herein by enclosing it in single brackets("[]"). A 

public version of these comments is also being filed with all confidential information removed. 

5