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 Version
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?

Public Version
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).

Public Version
 

 PUBLIC VERSION

 

 October 9, 2018 

The Honorable Robert E. Lighthizer 

United State Trade Representative

Office of the United States Trade Representative

600 17th Street NW 

Washington, DC 20508 

 

Re: Addendum to Request for Exclusion of Particular Products from the 

 Determination of Action Pursuant to Section 301

This letter is submitted by HL-A Co., Inc. (“HL-A” or “the Company”) pursuant to the 

Procedures to Consider Requests for Exclusion of Particular Products from the Determination of 

Action Pursuant to Section 301 as set forth in docket number USTR-2018-0025-0001. The 

information contained herein is an addendum to the individual product exclusion form, and is 

intended to address questions set forth in the procedures described above. For reference, this 

addendum pertains to certain key computer immobilizers that function as a key that can also 

automatically lock and unlock, as well as sound the panic alarm, of a vehicle. The products 

imported from China are classified under Harmonized Tariff Schedule of the United States 

(“HTSUS”) subheading 8526.92.5000 as “Radar apparatus, radio navigational aid apparatus and 

radio remote control apparatus: Other: Radio remote control apparatus: Other.” The following

discussion addresses specific information that is requested in the Federal Register Notice published 

on July 11, 2018 (83 Fed. Reg. 32181) concerning the three questions provided and responded to 

below. 

Consistent with the United States Trade Representative’s (“USTR”) procedures, we 

request confidential treatment for information designated as business confidential in this 

Public Version
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, product 

characteristics, and other sale-related business secrets, and the names of individuals or 

organizations that provided price, cost, and other market information. Business confidential 

information is indicated in the text below via single brackets ("[ ]"). Release of this information, 

including the identity of the submitter, would cause irreparable harm to the submitter. A public 

version of this Request is also being filed with all confidential information redacted.

The Products 

 By way of background on the Company, HL-A is an automotive supplier with plants in 

Bremen, Georgia, and Selma, Alabama. The Company employs [1,005] American workers in 

those plants. In fact, the plant in Bremen, Georgia is the largest employer in Haralson County, in 

which Bremen lies. 

The products that are the subject of this Request are certain key computer immobilizers

that function as a key that can automatically lock and unlock a vehicle, as well as sound its panic 

alarm. The products consists of a metal laser cut key combined with a transmitter and a case. The 

transmitter consists of a plastic casing, a printed circuit board, silicone buttons, and a button 

battery. The transmitter is used to send certain signals to a vehicle. These signals are the primary 

mechanism through with a person can lock or unlock a vehicle door and sound a panic alarm. The 

finished key computer immobilizers are solely for vehicles made through the 2012 model year. 

As such, they are manufactured solely as replacement vehicle keys for U.S. consumers. 

The specific HL-A part numbers for the key computer immobilizers that are the subject of this 

request are: [T2A-2A000-0400], [T2A-2A000-0900], [TY4-2A000-0000], [TY4-2A000-0100], 

[TY4-2A000-0200], [T0A-2A000-0N00], [TGG-2A000-0000], and [T2A-2A000-0500]. 

Public Version
A representiative picture of the key computer immobilizer is below:

[ ] 

Public Version
I. Whether the particular product is available only from China? 

The key computer immobilizer can only feasibly be supplied from China. China is the 

only country that already has the manufacturing plants, raw materials, and labor resources to 

sufficiently supply the subject product. The parts are designed in a unique manner that only exists 

in China. Transferring production to another country would cost the Company time and resources 

it does not have. 

The Company has spent many years cultivating its global sourcing network to meet 

demand. Currently, the subject products can only be produced by Chinese manufacturers at the 

capacity and pricing that the Company needs. Particularly, the subject products are unique in 

nature as it is designed for a specific automotive application. The unique tooling required to 

produce these products is only available in China. 

The Company does not know any manufacturer outside China that is currently able to 

produce these products at the capacity and quality needed. While possible, it would likely take a 

significant amount of time (e.g., several years) for any party to attempt to develop a factory outside 

China that would be able to suitably supply to the Company’s needs for the subject parts. Even 

then, the new manufacturer would have to go through the product testing process that HL-A 

demands of its suppliers. To that end, any party seeking to move the production of the subject 

products outside China would have to significantly invest in a plant’s unique tool and equipment 

machinery. Such an endeavor would likely be cost prohibitive. 

Public Version
Similarly, there is no domestic industry that can supply the Company with the subject 

products, because the products stopped being manufactured for mass production in 2012. We 

believe that it would be cost prohibitive for a domestic manufacturer to restart the manufacturing 

of these products in order to fulfill the Company’s limited replacement part needs, if it is even 

possible. Assuming a domestic manufacturer could potentially restart the supply of these products, 

it would likely take several years for the domestic supplier to adequately be able to supply HL-A. 

For these reasons, there is currently no way for the Company to source the subject products 

from outside China, whether it be from a third country or the United States, at the capacity needed. 

Therefore, the imposition of an additional 25 percent tariff on these products will be debilitating 

to the Company. As such, we urge USTR to grant HL-A the Section 301 exclusion requested 

herein. 

II. Whether the imposition of additional duties on the particular product would cause 

severe economic harm to the requestor or other U.S. interests? 

Not only would the additional 25 percent tariff imposed on the Company for the subject 

products significantly disrupt HL-A’s business, but it would have a devastating impact on the 

Company’s employees and customers. First, HL-A does not have the ability to withstand the 

additional tariffs for the subject products. As it is, the Company’s profits on these products are 

small. The Company projects that the imposition of the additional tariffs would cost the Company 

significantly more in the next twelve months. The Company would not be able to absorb the full 

amount of the additional tariffs, having already invested $126 million in its domestic operations, 

including a large investment in equipment in its facilities in Georgia and Alabama which is 

dedicated to the manufacturing of other mass produced parts. In light of this large investment, the 

additional tariffs imposed on the Company is too much to bear for this product. As such, it would 

have to pass on some or all of the additional tariffs to HL-A’s customers. 

Public Version
As a leader in the auto parts industry, the Company sells its finished keys to this country’s 

leading auto manufacturers. Without the steady supply of the subject products from China, these 

auto manufacturers would be forced to obtain the products from other companies at a higher price 

and lower quality. This would result in higher costs for HL-A’s customers and potential job losses 

that would likely negatively impact the U.S. consumer. 

HL-A employs Americans in Georgia and Alabama. The imposition of these additional 

tariffs would force the Company to import fewer and fewer of the subject products. As a result, 

employees in these plants in Georgia and Alabama would be negatively affected because the 

Company would not be able to sustain their employment. This would have a detrimental effect on 

those employees who depend on the steady pay-check they receive from the Company.

The extraordinary penalties the Company faces from these additional tariffs, and the 

inability to obtain these products elsewhere will impact the Company, the Company’s customers, 

and the Company’s employees. As such, we urge USTR to grant HL-A an exclusion from the 

Section 301 additional tariffs as requested herein.

III. Whether the particular product is strategically important or related to “Made in 

China 2025” or other Chinese industrial programs? 

HL-A’s key computer immobilizers are not included as part of China’s “Made in China 

2025” initiative. The goods are replacement keys for existing vehicles driven by U.S. consumers. 

Thus, imposing additional tariffs on these products from China would be ineffective in achieving 

the goals of the Section 301 investigation as the parts are not advanced technology. 

The subject products have been manufactured by HL-A’ssuppliers in China for many years

and the technology used to manufacture these parts has not changed in quite some time. The main 

focus of the “Made in China 2025” initiative, with respect to industrial applications, relates to 

Public Version
innovative, breakthrough technologies in the areas of green manufacturing or high-end 

development, not the mature technology at issue in this request. 

Further, HL-A is not subject to any foreign ownership or equity restrictions. There is no 

issue with Chinese policies forcing the Company to license technologies to Chinese entities. The 

Company licenses no technology to any entity in China. The Company also knows of no attempt 

by any Chinese entities to unfairly facilitate the systematic investment in, and acquisition of, HLA in order to obtain any sort of cutting-edge technological advantages. Finally, the Company has 

not witnessed any theft of its intellectual property by China.

For these reasons, the subject imports are not strategically important or related to China’s 

“Made in China 2025” initiative or other Chinese industrial programs. As such, we urge USTR to 

grant HL-A the exclusion requested herein.

Public Version