BUSINESS CONFIDENTIAL
$[110.64]

$[110.64]

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BUSINESS CONFIDENTIAL 20.0 

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Consistent with USTR's Section 301 notice, OMRON Management Center of America, Inc. 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.

[Total impact to OMRON's automotive business is $1.7 million under 301 action List 1, on $64 million

in sales.]

[Purchases of CASE,UPPER 5BTN RVSS are from our contract manufacturer. This inventory cannot be

purchased domestically or internationally elsewhere.] OMRON in the US is the only designer of this

product and only supplier of this component.

CASE,UPPER 5BTN RVSS is a molded plastic switch case, and is used only for automotive purposes to

house switches in a key fob, of which is an OEM-specified dimension. It is only used for further

assembly of components which go into domestic automobile production, which is specified by auto

manufacturer.

This product is not a target of the US Administration's 301 investigation regarding Intellectual Property

concerns. This is not a concern to IP transfer and impressment. This product contains no IP of interest

related to autonomous vehicle production.

The tariff action ultimately poses a risk of significant damage to OMRON [this division is 100% focused

on US and North American auto production, who only produces OEM components], the domestic

automobile industry [automotive clients are unable to re-source], and ultimately the US consumer as a

increase in price. [Movement of this product to Mexico or Canada would ultimately also lead to an

increased duty outlay, as the new proposed USMCA increases minimum content requirements on

switches and components.] Like in the case of similar approvals for vehicle components at the HTS

level, OMRON views this product in the same manner. Immediate movement of production to a US

manufacturer or another country would pose significant re-tooling costs [over $1 million], significant

amounts of time [movement of capital equipment and selection of a new site], and approvals pertaining

to consumer automobile safety standards are costly and would take a significant amount of time to

obtain.

OMRON Management Center of America, Inc. believes that CBP can easily exclude the CASE,UPPER

5BTN RVSS in question based solely on the product description. The following are draft CBP exclusion

instructions:

"CASE,UPPER 5BTN RVSS P Lucky Plastic "pear-shaped" raised edge flat molding with five button

holes hollowed out; two arranged next two each other at the top and two arranged on top of each other

below, and a fifth hollow hole at the bottom "Plastic case for REMOTE FUNCTION ACTUATOR -

made of resin - ABS+PC" Dimensions 42m x57.23mm x8.12mm."

This information will be contained on the invoice from the supplier.

BUSINESS CONFIDENTIAL