Polaris -Addendum for Recreational Utility Vehicle 

PUBLIC VERSION 

0POLRRIS® 

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 ATV categories year after year, developing the first purpose-built ultra-light military vehicles, or 

introducing a radical 3-wheel moto-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 manufacturingjobs. 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 exclusion criteria available under the 

Section 301 process. [ 
Polaris - Addendum for Recreational Utility Vehicle 

PUBLIC VERSION 

II. Specific Exclusion Request for Recreational Utility Vehicle. 

A. Recreational Utility Vehicle Should Be Excluded Because They Are Produced at 

Polaris' Wholly-Owned Chinese Subsidiary and All Other Comparable Products 

Also Are Produced in China 

Small recreational utility vehicles are a discretionary item that need to hit a price point that consumers 

can afford and are willing to pay. 

In 2015, Polaris acquired a manufacturing facility in Shanghai that produces go karts and recreational 

utility vehicles. YiXing (Hammerhead), which is a wholly-owned subsidiary of Polaris, manufactures 

Polaris' go karts and recreational utility vehicles, which are imported by Polaris' affiliate (Polaris Sales 

Inc.) and sold in the United States. Given that Polaris recently acquired its wholly-foreign owned 

subsidiary so it could supply vehicles to Polaris in the United States, Polaris respectfully requests that 

USTR grant this exclusion request. 

Products manufactured in China by wholly-owned foreign enterprises ("WFOES") of U.S. companies 

should be excluded from Section 301 tariffs. Imposing the additional duties on products manufactured 

by wholly-owned subsidiaries of U.S. corporations is not an appropriate means of eliminating the 

policies and practices cited by USTR in the Section 301 report, as long as the wholly-owned subsidiary 

was not required by China to surrender involuntarily their U.S. technology. 

o Section Il(B) of the Section 301 determination is entirely focused on the extent to which 

China uses foreign-ownership restrictions as part of a regime to obtain forced technology 

transfer. In view of this, we respectfully submit that it would be illogical, unfair, and 

inappropriate to penalize companies which manufacture in China under conditions 

consistent with the end goals of the Section 301 determination (i.e., in WFOEs, without 

involuntary technology transfers) in order to achieve those goals. 

o From an economic standpoint, the proposed $50 billion (or $250 billion) in Section 301 

duties will only be effective to the extent it targets goods for which there is elastic (rather 

than inelastic) demand. The publicly-stated purpose of the Section 301 duties is to make 

it economically infeasible to source covered goods from China, leading to an immediate 

reduction in the U.S. bilateral trade deficit with China, and thereby serve as a meaningful 

incentive for China to remedy the harm cited in the Section 301 determination. 

o Because a U.S. company's demand for goods produced by its own wholly-owned 

Chinese subsidiary is highly inelastic, imposing duties on goods manufactured by 

WFOEs will be ineffective in achieving the stated goals. Although a company could 

potentially restructure part of its supply chain in response to the Section 301 duties, it is 

unrealistic to expect that imposing Section 301 duties on goods imported from WFOEs 

will result in U.S. companies ceasing to utilize their own wholly-owned Chinese 

factories. As a general proposition, businesses that operate through WFOEs in China are 

significantly invested in their Chinese operations, and cannot afford to terminate such 

operations pursuant to changes in U.S. trade policy. Additional duties of 25 percent will, 

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Polaris - Addendum for Recreational Utility Vehicle 

PUBLIC VERSION 

thus, harm the U.S. company that made the investment in the first place. Moreover, it 

will harm U.S. jobs that support R&D, product development and engineering for the 

wholly-owned Chinese subsidiary and factory. 

o Exempting products manufactured by WFOEs would also be relatively easy to administer 

by CBP. Companies could certify as part of the customs entry process (as is done with 

free trade agreement claims) that articles have been manufactured by a WFOE and the 

WFOE had not been subjected to involuntary technology transfers in China. Such a 

certification would be subject to audit/verification by CBP. The manufacturer 

identification (MID) codes (which are part of existing customs entry declarations) could 

help ensure that only articles produced by the WFOE were entered under the exemption. 

B. Additional Information about Product Description (Question 2) 

The product for which the exclusion request is being submitted is for an recreational utility vehicle, 

which is a light-duty utility vehicle, typically used for recreational trail riding on private property, with a 

9 horsepower, 4-stroke engine with 149-cc displacement, air/oil cooling, hydraulic front and rear brakes, 

automatic continuously variable transmission clutch, rear two-wheel drive, dual A-arm front suspension 

and swing arm rear suspension, rack and pinion steering, 5-point metal latch and link seatbelt, rear view 

mirrors, dump bed, hard top, with the following dimensions: a length of 95 inches, a width of 51 inches, 

and a height of 74 inches. 

The following is a picture of the recreational utility vehicle meeting the above physical description: 

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Polaris - Addendum for Recreational Utility Vehicle 

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Additional Information about 

C. Impact on Polaris (Question 11) 

To the extent that additional duties are applied on vehicles produced by Hammerhead, it [ 

]. 

Section III contains additional information concerning the impact on Polaris of the Section 301 duties. 

D. Information about Intellectual Property and Made in China 2025 

Recreational utility vehicles typically are not sold in China. None of the intellectual property is 

advanced or strategic. The engines are scooter engines. None of the technology is covered by China's 

Made in China 2025 policies. Moreover, as stated above, Hammerhead is a wholly-owned subsidiary of 

Polaris. There was no forced technology transfer. To the contrary, Polaris purchased Hammerhead due 

to the type of recreational utility vehicles and other vehicles it was producing. 

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Polaris - Addendum for Recreational Utility Vehicle 

PUBLIC VERSION 

E. Draft CBP Language 

Polaris believes that CBP can easily exclude the recreational utility vehicle in question based solely on 

the product description. The following are draft CBP exclusion instructions: 

Excluded from the Section 301 tariffs are light-duty recreational utility vehicle, typically used 

for recreational trail riding on private property, with a 9 horsepower, 4-stroke engine with 149-cc 

displacement, air/oil cooling, hydraulic front and rear brakes, automatic continuously variable 

transmission clutch, rear two-wheel drive, dual A-arm front suspension and swing arm rear 

suspension, rack and pinion steering, 5-point metal latch and link seatbelt, rear view mirrors, 

dump bed, hard top, with the following dimensions: a length of 95 inches, a width of 51 inches, 

and a height of 74 inches. 

This information will be contained in the instruction manual that accompanies the recreational utility 

vehicle. 

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. Immediate Reliefls Needed 

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

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Polaris - Addendum for Recreational Utility Vehicle 

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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. 

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