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):

PUBLIC VERSION
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:

PUBLIC VERSION
33165726 

1700 Pennsylvania Avenue, N.W.

Washington, DC 20006-4706

(202) 737-0500 (telephone)

(202) 626-3737 (fax)

www.kslaw.com

Stephen J. Orava 

Direct Dial: (202) 661-7937 

sorava@kslaw.com

October 8, 2018

VIA REGULATIONS.GOV 

The Honorable Robert E. Lighthizer

United States Trade Representative

Office of the U.S. Trade Representative 

600 17th Street, N.W.

Washington, DC 20508

Docket No. USTR–2018–0025

PUBLIC VERSION

Re: Section 301 Investigation: China's Acts, Policies, and Practices Related to 

Technology Transfer, Intellectual Property, and Innovation / Request For 

Exclusion From Additional Duties 

Dear Ambassador Lighthizer: 

Honeywell International Inc. (“Honeywell”) files this request for exclusion from 

additional duties for certain piezo-resistive board mount pressure sensors imported from China.

This request is being made pursuant to the procedures announced on July 11, 2018.1

Honeywell is a U.S. manufacturer of a variety of products, ranging from HVAC 

accessories and work wear, to advanced aerospace technology. Honeywell operates production 

facilities in Georgia, South Carolina, New York, New Jersey, Pennsylvania, and Washington, 

and it employs 46,000 people in the United States. 

1

Procedures to Consider Requests 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. 32181 (July 11, 2018).

PUBLIC VERSION
33165726 

The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 2 

Honeywell invents and manufactures technologies that address some of the world’s most 

critical challenges around energy, safety, security, productivity and global urbanization. It prides 

itself in being at the forefront of blending physical products with software to support connected 

systems that improve homes, buildings, factories, utilities, vehicles and aircraft, and that enable a 

safer, more comfortable and more productive world. Honeywell’s solutions enhance the quality 

of life of people around the globe and create new markets and even new industries. 

Honeywell requests an exclusion from additional duties (effective from July 6, 2018 until 

one year after the publication of the exclusion determination) for imports of piezo-resistive board

mount pressure sensors from China. The piezo-resistive board mount pressure sensors imported

by Honeywell are not manufactured in the United States, and components with the unique 

combination of characteristics comparable to Honeywell’s piezo-resistive board mount pressure

sensors are not available anywhere in the world. Access to Honeywell’s components gives 

customers a competitive advantage in their U.S. manufacturing and in their U.S. exports around 

the world. The additional details requested by your office are provided below. 

I. IDENTIFICATION OF THE PRODUCT SUBJECT TO THE EXCLUSION

REQUEST – PIEZO-RESISTIVE BOARD MOUNT PRESSURE SENSORS

A. General Description

The product for which exclusion is requested is piezo-resistive board mount pressure 

sensors. These sensors are used in a variety of consumer, medical, and industrial applications to 

measure the pressure of gases and liquids in items such as dishwashers, blood pressure monitors, 

and air braking systems, respectively. 

PUBLIC VERSION
The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 3 

This group of sensors all function using the same basic physical principle of piezoresistance. The piezo-resistive effect is a change in the electrical resistivity of a semiconductor or 

metal when mechanical strain is applied. 

The fundamental sensor element in these products is a monocrystalline silicon 

semiconductor wafer manufactured using semiconductor technology. Alhough manufactured 

with semiconductor technology, the wafers also operate on the resistive principle and produce a 

piezoelectric effect. Conductivity in a doped semiconductor is influenced by a change 

(compression or stretching of the crystal grid) that can be produced by an extremely small 

mechanical deformation. As a result, the sensitivity of monocrystalline sensors is higher than 

that of most other types. These monocrystalline silicon semiconductor wafers are manufactured 

in the United States, and Honeywell retains control of this technology. Honeywell ships these 

wafers to China for packaging, an important but less technologically sophisticated process than 

producing the wafers. As a general matter, packaging a wafer allows the sensor technology to 

connect to and be integrated into a variety of products and systems through the addition of pins, 

threaded housings, and the like. 

These sensors are designed to be mounted on printed circuit boards (“PCBs”). 

Accordingly, these sensors have very small form factors because PCBs impose important 

limiting constraints on space and weight. These sensors also consume relatively small amounts 

of electrical power. These products are designed for use in environments that do not involve 

extremes in conditions, such as temperature and corrosiveness. 

These sensors are compliant with RoHS (Restriction of Hazardous Substances) regarding 

maximum levels of 10 substances, such as lead and cadmium, and REACH (Regulation for 

Registration, Evaluation, and Authorization of Chemicals) in the European Union. 

33165726 

PUBLIC VERSION
33165726 

The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 4 

These sensors are described in further detail in Honeywell’s datasheet on Basic Board 

Mount Pressure Sensors (https://sensing.honeywell.com/honeywell-sensing-basic-board-mountpressure-sensors-nbp-datasheet-32302908-a-en3.pdf).

B. Specific Description For Customs Purposes

The following product description may be used by U.S. Customs and Border Protection 

(“CBP”) to administer the exclusion:

Piezo-resistive board mount pressure sensors utilizing the physical 

principle of a change in the electrical resistivity of a semiconductor 

or metal when mechanical strain is applied. These sensors may 

only be mounted on printed circuit boards (PCBs). These sensors 

are compliant with RoHS (Restriction of Hazardous Substances) 

regarding maximum levels of 10 substances such as lead and 

cadmium and REACH (Regulation for Registration, Evaluation, 

and Authorization of Chemicals) in the European Union. 

C. The Applicable HTSUS 10-Digit Subheading

The piezo-resistive board mount pressure sensors subject to this exclusion request fall 

within the 10-digit HTSUS subheading 9026.20.4000. This subheading provides for electrical 

instruments and apparatus for measuring or checking the pressure of liquids or gases. 

II. COMPARABLE PIEZO-RESISTIVE BOARD MOUNT PRESSURE SENSORS

ARE NOT AVAILABLE IN THE UNITED STATES OR FROM THIRD

COUNTRIES

The piezo-resistive board mount pressure sensors described are unique to Honeywell and

produced specifically to Honeywell’s rigorous standards and proprietary requirements. These 

piezo-resistive board mount pressure sensors are not commodity goods, and precise substitutes 

are not produced anywhere else in the world. As noted above, the underlying sensor technology 

is manufactured by Honeywell in the United States to the company’s proprietary standards and 

packaged to Honeywell’s specifications in China. Other companies manufacture sensors that are 

functional substitutes in a general sense only. 

PUBLIC VERSION
The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 5 

33165726 

III. IMPOSITION OF ADDITIONAL DUTIES ON PIEZO-RESISTIVE BOARD

MOUNT PRESSURE SENSORS WOULD CAUSE SEVERE ECONOMIC HARM

TO HONEYWELL AND ITS CUSTOMERS

 The imposition of additional duties would cause severe economic harm to Honeywell 

and its many U.S. customers in a multitude of industries, including those producing products for 

domestic and export sale. Honeywell alone would face millions of dollars in additional costs, 

and increased prices from the additional duties would undermine the competitive advantage of 

Honeywell’s U.S. manufacturer customers in the U.S. and critical export markets. Many of 

those U.S. manufacturers are already vulnerable because of unfairly traded imports and Chinese 

industrial policies. The imposition of additional duties will undermine U.S. industries’ access to 

high quality piezo-resistive board mount pressure sensors necessary to preserve and increase 

their competitive advantage. Thus, imposition of the additional duties on imports of Piezoresistive board mount pressure sensors from China would cause severe economic harm to both 

Honeywell and its numerous U.S. customers in a variety of industries. 

IV. AN EXCLUSION FOR PIEZO-RESISTIVE BOARD MOUNT PRESSURE

SENSORS WOULD NOT UNDERMINE THE OBJECTIVES OF THE SECTION

301 ACTION

USTR should grant an exclusion for Honeywell’s piezo-resistive board mount pressure

sensors because an exclusion for this product would not undermine the objectives of the Section 

301 action. The Section 301 action is aimed, in part, at combatting forced technology transfer of 

industrial significant technologies from U.S. companies to Chinese entities. With respect to the 

manufacture of Honeywell’s piezo-resistive board mount pressure sensors, no advanced 

technology or technical know-how has been transferred outside Honeywell. The valuable 

technology and intellectual property involved in the design and manufacture of the silicon wafer 

PUBLIC VERSION
33165726 

The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 6 

remain controlled by Honeywell, and imposition of additional tariffs on piezo-resistive board 

mount pressure sensors would not impact China’s technology transfer practices. 

V. THE PIEZO-RESISTIVE BOARD MOUNT PRESSURE SENSORS ARE NOT

STRATEGIC TO CHINA’S “MADE IN CHINA 2025” OR OTHER

INDUSTRIAL PROGRAMS

The specific products requested to be excluded are not strategic to the Made in China

2025 initiative or other Chinese industrial programs. The imposition of additional tariffs now

on the piezo-resistive board mount pressure sensors would not impact in any material way 

China’s policies, and such policies are more likely to be affected, if at all, by sustained, 

comprehensive, and multilateral efforts. Imposition of additional tariffs would, however, 

have a significant detrimental impact on Honeywell and lits customers. Accordingly, 

increased tariffs would not alter Chinese policies, would increase Honeywell’s costs, and 

would decrease its competitive position. 

VI. CBP CAN READILY ADMINISTER THE EXCLUSION FOR PIEZO-RESISTIVE

BOARD MOUNT PRESSURE SENSORS

CBP would be able to administer the requested exclusion because the piezo-resistive

board mount pressure sensors are identified on documentation that does or can accompany the

entry, which identify the components listed above. 

VII. IMPORT DATA APPLICABLE TO PIEZO-RESISTIVE BOARD MOUNT

PRESSURE SENSORS

Please see the table below for quantity and value data for imports of piezo-resistive board

mount pressure sensors originating from China over the past three years. 

PUBLIC VERSION
The Honorable Robert E. Lighthizer 

October 8, 2018 

Page 7 

33165726 

Year Quantity Value

2015 [ ] [ ]

2016 [ ] [ ]

2017 [ ] [ ]

VIII. CONCLUSION

For all of the above reasons, we request an exclusion from additional duties on imports of

the above-described piezo-resistive board mount pressure sensors from China. Please contact us 

if you have questions about this submission. 

Respectfully submitted, 

Stephen J. Orava 

Partner 

PUBLIC VERSION
CERTIFICATION 

I, Robert Robinson of Honeywell International Inc., certify that the information 

contained in this submission is accurate and complete to the best ofmy knowledge. I also 

certify that disclosure of the information marked "business confidential" would endanger 

trade secrets or profitability, and that the information would not customarily be released to 

the public.

Date: __ O_c._+ __ 5_+e. __ .Q_o_1 __ %"_

PUBLIC VERSION