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:
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

October 6, 2018 

VIA REGULATIONS.GOV PUBLIC DOCUMENT

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025 

U.S. Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Re: Request for Exclusion of Terminals, Electrical Splices and Electrical Couplings under HTSUS 

8536.90.4000 from the Determination of Action Pursuant to Section 301

Dear Ambassador Lighthizer:

Scosche Industries, Inc. (“Scosche”) respectfully submits this request for exclusion of Terminals, 

Electrical Splices and Electrical Couplings from the proposed determination of action pursuant to Section 301 

of the Trade Act of 1974.1

 

Scosche was founded in 1980 as a family-owned and operated enterprise, and is based in Oxnard, 

California. Scosche is an internationally recognized, award-winning innovator of consumer technology and car 

audio products. We maintain offices in three U.S. States plus Shenzhen, China and have over 140 employees 

located in four countries. 

Scosche provides car audio installation hardware and portable electronics accessories. It offers dash kits, 

harnesses, antennas and adapters, tools, amplifiers, speakers, subwoofers, speaker enclosures, Bluetooth 

products, interfaces, distribution blocks, power and audio cables, mobile accessories, and installation 

 

1

 19 U.S.C. § 2411. 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

accessories. Scosche’s product portfolio encompasses thousands of skus spanning the consumer technology and 

car audio arena. Scosche products are sold in over 50 countries by a wide array of the most recognized names 

in retail.

This exclusion request addresses Terminals, Electrical Splices and Electrical Couplings classified under 

HTSUS subheading 8536.90.4000, which are currently subject to the 25% additional Section 301 tariff. Please 

note that a separate Section 301 Investigation Form to Request Exclusion of Product has been submitted for 

each unique part number for which we are requesting an exclusion. 

In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2

 Scosche provides the following information requested by the USTR in support of this request. 

1. Availability of the product outside of China, i.e. whether the particular product and/or a 

comparable product is available from sources in the United States and/or in third countries

The Terminals, Electrical Splices and Electrical Couplings that are the subject of this exclusion request 

are not available outside of China. Currently, our company sources Terminals, Electrical Splices and Electrical 

Couplings from extensively vetted suppliers in China. There is no readily available alternative U.S. or third 

country source outside of China from whom we can source these products. 

Further, the Terminals, Electrical Splices and Electrical Couplings have not been sourced in other 

countries as all of our tooling, certifications and logistics for this product are located in China. To engage new 

suppliers would entail an onerous process of: identifying vertically integrated suppliers, including sub-suppliers, 

 

2 Procedures To Consider Requests for Exclusion of Particular Products From the Determination of Action 

Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual 

Property, and Innovation, 83 Fed. Reg. 32,181 (USTR July 11, 2018). 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

in other countries; once identified, making sure such suppliers maintain facilities that adhere to labor laws 

consistent with U.S. standards; retooling the product. Our current suppliers have passed vital social 

responsibility, safety and security audits required by U.S. retailers. Scosche is contractually required to use 

audited, certified and approved suppliers. Our suppliers have already been qualified and to change suppliers 

would require us to repeat this process and request a contractual amendments from our customers. 

With new suppliers, we would have to recertify the products and produce them. Our whole 

infrastructure would be in jeopardy. To do so, would take a minimum of two years, in addition to another year 

of social responsibility, security and safety audit standards. Lead times will more than double due to supply 

chain constraints and lack of vertical integration. 

Given its reliance on its current supply chain in China, Scosche has significant capital investment in 

tooling in China. To relocate its tooling outside of China, Scosche would cause extended interruptions to our 

production. To mitigate the impact of such interruptions, Scosche would need to make significant capital 

expenditures to duplicate its tooling in multiple locations, which would cause extreme financial hardship to our 

company. 

Our practice of importing Terminals, Electrical Splices and Electrical Couplings is consistent with that 

of our leading competitors. 

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

economic harm to the requester or other US interests 

The Terminals, Electrical Splices and Electrical Couplings facilitate the installation of aftermarket car 

audio systems. These products are sold in mass merchant retail with a slim profit margin, providing low pricing 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

to the end consumer. Although the Terminals, Electrical Splices and Electrical Couplings do not support any 

down-stream manufacturing in the U.S., they are a key innovation to the American consumer electronics 

experience. 

The imposition of a 25% duty increase would have a negative impact on our U.S. profits and 

employment. The Terminals, Electrical Splices and Electrical Couplings are sold in mass merchant retail with a 

slim profit margin resulting in low pricing to the end consumer. These products are not an absolute necessity 

but they do provide consumers added convenience and an enhanced consumer experience. If the pricing 

increases, consumers may simply decide to no longer use our product. As a major supplier of Walmart, 

BestBuy, and Target etc., the ramifications of losing this line of business would be devastating to Scosche and 

its employees.

The imposition of a 25% duty increase effectively negates our low profit margin, which would, by 

necessity, be passed directly to our retail customers who have confirmed that increased costs would ultimately 

be passed on to end consumers. Many of our customers have communicated directly with legislators on this 

extremely important issue. These tariffs will directly affect our bottom line, profit sharing and employment 

budget. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or 

other Chinese industrial programs

The Terminals, Electrical Splices and Electrical Couplings are not strategically important, nor related to 

any other Chinese industrial programs, including “Made in China 2025.” Specifically, the Terminals, Electrical 

Splices and Electrical Couplings are not a low technology product but they are imported to facilitate the 

~ ~LCJ~C? II=* 

ACCESSORIES FOR LIFETM 
Mailing: PO Box 2901, Oxnard, CA 93034 Corporate: 1550 Pacific Ave, Oxnard, CA 93033 t: 800.363.4490 f: 805.486.9996 www.scosche.com

implementation of high technology replacement stereo head units in the United States. The product is produced 

by a non-affiliated third party supplier. There are no U.S. patents or trademarks covering this product, and no 

intellectual property rights have been transferred to Chinese producers. These Terminals, Electrical Splices and 

Electrical Couplings are produced in China to our specifications and for our exclusive use. 

We have transferred no intellectual property rights to our suppliers in China nor are we required or 

expected to do so. 

We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

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

 Respectfully submitted,

 

 ___________________ 

 Christopher Norris 

 Global Logistics Coordinator

 Scosche Industries

 (800) 363-4490, 122 

 chrisn@scosche.com 

~ ~LCJ~C? II=* 

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