Organization Name:

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

Requestor Representative:

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.

3.

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

4.

*

10-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/

7.

5. Requestor's relationship to the product:

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

Please indicate whether any additional attachment contains business confidential information 

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

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1

Public Document

Machined Aluminum Permanent Mold Casting. SAE J452 UNS AO3190-F. Weight 1.28 kgs. 

Thermostat housing.

8481909060 Jeffries, Timothy Stant Corporation Purchaser NON/A
8. Is this product, or a comparable product, available from sources in the United States? (If you

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

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:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?

NONO 3436000 200000 3526000 200000 3616000 200000 INPUT52% 2.7%
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).

This is a custom product with geometry intended for use in only one application with tooling specific for 

its production and the platform it applies to. The tooling cannot be moved to another supplier. New 

tooling would be an additional expense and would not be approved for production prior to this program 

ending regular production at the beginning of 2020. Considering this, the product is not available from 

another source in the United States or a third country. 

Will additional duties cause severe economic harm to the requestor or other U.S. interests? - Yes, this 

impacts our profitability and our customers. 

Is the particular product strategically important or related to “Made in China 2025” or other Chinese 

industrial programs? - No, one summary of "Made in China 2025" I've read states "the goal is to 

comprehensively upgrade Chinese industry, making it more efficient and integrated so that it can occupy 

the highest parts of global production chains." These casting components are at the lowest level of the 

Bill Of Material in our assembly. They are minimally value-add and certainly not driven by 

technological advancement. Also, again, they have no impact on China's 2025 goals because production 

will have ended by that time regardless and only service requirements will be in place at much lower 

volumes. 

Annual values and quantities are based on customer provided program details. 

The information provided is certified complete and correct to best of my knowledge.