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 product of concern:

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

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.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

8. Is this product, or a comparable product, available from sources in the United States?:

VERSION 1

11. Please provide information in support your request, taking account of the instructions

provided in Section B of the Federal Register notice (note: text entered below can extend

beyond the apparent size of this box).

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

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:
Attachment 1 to 8479909496 Alter Trading Shredder Parts (Caps) P

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Attachment 1 to 8479909496 Alter Trading Shredder Parts (Caps) P

Founded in 1898, Alter Trading Corporation is a privately owned, fifth-generation company, and one of the 

largest recyclers in the nation. Alter operates 70 metal recycling facilities under the trade name Alter Metal 

Recycling in ten states, as well as representative sales offices in Hong Kong and Shanghai. Headquartered in 

St. Louis, MO, Alter provides a direct supply of quality products and services, sourced both in America and 

aboard, to consumers in the United States and throughout the world. 

Properly handled, scrap metal is a continuous and valuable resource that can be re-melted and reshaped into 

new products countless times while providing significant economic and environmental benefits as compared 

to virgin materials. Alter collects, processes and recycles metals ranging from iron and steel to aluminum, 

copper, lead, stainless steel and zinc, which it then provides to mills and foundries for use in the production of 

new steel and other metal products.

One of the principal sources of supply for the scrap metal Alter processes at its U.S. facilities is end-of-life 

vehicles. The processing of vehicles within an Alter recycling facility relies on several distinct processes, 

including shredding. Shredding is accomplished through the use of auto shredders with the Caps (end disc & 

spider rotor), the subject of this exclusion request representing one of the wear parts essential to the breaking 

down of each vehicle to prepare the metal for repurposing into new steel and other metal products. An image 

of that part is provided below:

End Disc Cap

Spider Cap

Shredder wear parts are generally made of three types of material that have an effect on cost. The majority of 

these replacement components are made of manganese steel that absorbs impact and is resistant to abrasion, 

and thus can process metal scrap up to three times the hardness of the parts. The second type is made of alloy 

steel that can be used to make caps, as well as hammers, liners, grates and anvils (other parts for which we are 

requesting exclusions). Alloy steel hammers, for example, as the main part used to shred autos, are used to 

process lighter gauge scrap. These hammers cost more than hammers made of manganese steel. The 

hardness of the alloy hammers makes them brittle and sustainable to premature failure when exposed to 

excessive hard metals, as occurs when shredding metal. As alloy hammers are not economical to use in 

shredders, the same applies to all other wear part components of the shredder, including caps. The third type, 
Attachment 1 to 8479909496 Alter Trading Shredder Parts (Caps) P

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differentially heat-treated alloy – or DHT – is a material also used for caps. DHT caps are nearly twice as hard as 

traditional manganese alloy caps, requiring a four-step heat-treating process (as compared to a single-step 

heat-treating process for traditional manganese alloy caps). The process creates a significantly harder wear 

component with a better wear life span but also a much higher cost than both manganese and alloy parts. 

Manganese parts are one-third to one-half the price of the alternatives and, therefore, are a preferred option 

where wear part production is concerned. With more than 90% of the manganese steel parts used in the 

United States manufactured in China, turning to Chinese producers of these components is the only reliable 

option available in today's marketplace. This is not to say that auto shredders and parts suppliers have not 

tried to find additional suppliers to diversify the purchasing of these parts. There is one foundry in the United 

States, but the operation is too small to meet the requirements of all shredders operating in the United States.

As of October 2018, their lead time to delivery required parts is 50 weeks, whereas typical times from China 

are 18-24 weeks. Germany is a source of the higher priced DHT hammers and has a small niche customer base 

in the United States. Foundries in Canada and Peru can meet quality standards, but are smaller operations 

that provide significantly higher-priced products and do not have the production capacity to satisfy continuous

U.S. demand. Foundries in India, Middle East, Mexico, Malaysia and Australia have been approached, but 

similar capacity constraints, as well as higher prices, quality issues or a combination of these limitations has 

prevented U.S. companies from establishing long-term arrangements to purchase their products. Finally, even 

were a viable alternative identified, transitioning from existing suppliers to a new supplier situated outside of 

China cannot be accomplished lightly, as it requires a significant investment in design, development and 

testing before final approval for the on-going production and supply of wear parts may be achieved. In the 

end, therefore, auto shredders in the United States must source about 81-85% of their parts from China in 

order to remain competitive and satisfy customer needs. 

Given the repetitive need for these wear parts, the 25% tariff imposed under Section 301 has already had a 

significant adverse financial impact on Alter Trading. [ 

 .] Auto shredders are operating in an 

extremely cost-conscious environment, and are already combatting increases in transportation, energy, fuel 

and labor costs. The addition of these tariffs to that cost structure promises to – at the least – inhibit Alter 

Trading’s on-going ability to supply its steel mill and foundry customers and – at the most – result in increased 

cost to those customers who are, themselves, seeking to recover their own production footprint in the United 

States. In either instance, an industry which the Administration has strongly targeted and supported as a key 

partner in the resurgence of U.S. industry will be harmed. Taken in totality, we respectfully request that this 

exclusion request be granted so that the auto shredder industry may remain cost-competitive and the ongoing supply of recycled steel and other metal products to U.S. mills and foundries preserved.

While we respectfully submit that these reasons alone are sufficient to grant Alter Trading's request for a 

product exclusion, as a mid-sized business heavily invested in the United States, the continued imposition of 

this tariff on Alter Trading's auto shredder wear part imports will not eliminate the harmful and unfair 

practices associated with China that were identified by USTR in its Section 301 Report. The production of 

these wear parts does not fall within any of the 10 categories identified by China as part of its Made in China 

2025 industrial plan and will not, therefore, further those ambitions in any substantive way. Nor, for that 

matter, is the production of the wear part the result of any of the unfair trade practices identified by USTR in 

its report on China's "Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and 

Innovation." Although the technology used to shred is proprietary based on Alter Trading's internallydeveloped intellectual property, the production of these items is not in and of itself controlled. Given these 

facts, the continued imposition of additional duties at the 25% level on Alter Trading's wear parts imports will 

not have any practical impact on the elimination of China's unfair trade practices.
Attachment 1 to 8479909496 Alter Trading Shredder Parts (Caps) P

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I hereby certify that the information provided is complete and correct to the best of my knowledge. The 

bracketed information set forth in this submission is business confidential to Alter Trading, and the disclosure 

to any third party would compromise Alter Trading's competitive position, which would adversely affect the 

Company's financial and operational performance. The bracketed information is neither subject to public 

disclosure nor disclosed to the public; it remains confidential at all times to the internal management and 

business operations of Alter Trading.