PUBLIC VERSION 

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. 

!Public Version of BCI 

2. Please provide a complete and detailed description of the particular product of concern: 

Parts for hydraulic fluid pumps. 

3. IO-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/ 

8413919050 

4. Requestor Information 

Requestor Name (Last, First): !Paul Vitrano 

::::=======================================::::: Organization Name: !Polaris Industries, Inc. 

Note: Representatives submitting on behalf of an organization must enter information below. 

Requester Representative: !Drinker Biddle & Reath LLP 

5. Requestor's relationship to the product: ._!I_m.._p_o_rt_e_r _________________ __. 

6. Does this submission in regulations.gov include additional attachments? 

7. Please indicate whether any additional attachment contains business confidential information 

(BCI), is a public document, or is a public version of a BCI document. 

!Public Version of BC! 

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PUBLIC VERSION 

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

indicate "NO", you must provide support for your assertion in Box 12). 

!YES 

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

indicate "NO", you must provide support for your assertion in Box 12). 

!YES 

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: [*******] units 

2016 Quantity: [*******] units 

2015 Quantity: [*******] units 

11. Is the Chinese-origin product of concern sold as a final product or an input used in 

the production of a final product or products? 

INPUT 

a) For imports sold as final products, please provide: 

% of your total gross sales in 2017 that the Chinese-origin product accounted for. 

b) For imports of inputs used in the production of final products, please provide: 

[ ]% 

[** **]% 

VERSI0N2 

% 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. 

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

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). 

See attached addendum. 

Consistent with USTR's Section 301 notice, Polaris 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 infonnation removed. 

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Polaris - Addendum for Parts for Hydraulic Fluid Pumps 

PUBLIC VERSION 

0PDLARIS® 

I. Executive Summary 

Polaris Industries Inc. ("Polaris") is a stalwart U.S. manufacturing company that represents the 

U.S. paradigm of a strong American brand competing and winning in the global marketplace. 

Our vision is to fuel the passion of riders, workers and outdoor enthusiasts around the world by 

delivering innovative, high-quality vehicles, products, services, and experiences that enrich their 

lives. 

Our company has become synonymous with adventure and passion, in both work and play. For 

nearly 65 years, we have been making high-quality, breakthrough products-whether launching 

the snowmobile industry, reinventing ATV categories year after year, developing the first 

purpose-built ultra-light military vehicles, or introducing a radical 3-wheel moto-roadster. 

Polaris stands firmly behind the Administration's goal of freer and fairer global trade based on a 

rules-based system by which all countries must abide. We greatly appreciate the commitment of 

the President and his Administration to strengthening U.S. manufacturing and supporting 

American manufacturing jobs. We also support the Administration's goal of holding countries 

and competitors accountable to playing by the rules. Placing all industry on a level playing field 

allows capitalism to flourish, and we are confident Polaris will succeed in that environment. 

Polaris, however, respectfully requests that USTR mitigate the adverse impacts of the Section 

301 tariffs on Polaris' U.S. manufacturing operations. Mitigating those impacts will avoid the 

unintended consequence of providing foreign competitors, which manufacture outside the United 

States, a competitive advantage over Polaris and its U.S.-produced vehicles. 

USTR can minimize the potential harm to U.S. manufacturers like Polaris by (1) granting the 

product-specific exclusions requested in this and other submissions; and (2) expanding the 

exclusion criteria available under the Section 301 process. [ 

] 

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Polaris -Addendum for Parts for Hydraulic Fluid Pumps 

PUBLIC VERSION 

II. Specific Exclusion Request for Pump Parts 

A. Information about Intellectual Property and Made in China 2025 

Pumps are not high technology products. Polaris has been using the same pump design and 

manufacturing methods for many years. Pump parts are made of steel and aluminum. These are 

not products implicated by China's "Made in China 2025" policies. Pump parts are a low skill 

labor, low intellectual property manufacturing input. Polaris is not aware of any specific 

technology being developed in China that will advance the use of pumps or eliminate the use of 

pumps in our products. 

B. Draft CBP Language 

Polaris believes that CBP can easily exclude the pump parts in question based solely on the 

HTSUS code given that the parts are specifically classified at the 10-digit level of HTSUS 

8413.91.9050, having a description of parts for hydraulic fluid pumps. 

ill. Polaris Requests that USTR Mitigate the Adverse Impact of the Section 301 Retaliatory 

Duties on U.S. Manufacturers 

A. Polaris is a Proud U.S. Manufacturer and Supports the Administration's 

Efforts to Create Free and Fair Trade 

Polaris is proud to be part of the storied history, and promising future, of U.S. manufacturing. 

We employ over 9,000 Americans, including 5,800 manufacturing workers, and willingly 

shoulder the responsibility of preserving their jobs and, through growth, creating even more. We 

pay competitive wages, [ ] 

and grant stock to our employees, making our employee stock ownership plan Polaris' fourth 

largest shareholder. 

Polaris exemplifies American manufacturing and pro-American sourcing. Polaris proudly 

manufactures vehicles and engines at six U.S. factories in Huntsville, Alabama; Anahe im, 

California; Elkhart, Indiana; Spirit Lake, Iowa; Roseau, Minnesota; and Osceola, Wisconsin. 

Polaris also buys from suppliers in the United States to make our vehicles and engines and sells 

Polaris vehicles to consumers through independent dealers throughout the United States. [ 

] We recently built the $190 million Huntsville plant and 

are currently constructing a $50 million distribution center in Fernley, Nevada. 

Polaris' history proves that manufacturing generates wealth, and we know that a strong 

production sector is the backbone of a flourishing economy. However, without free and fair 

trade, U.S. products find themselves at a disadvantage in a worldwide market rife with 

government subsidies and punitive tariffs. This Administration understands the necessity of fair 

trade. It is admirably working toward instituting modernized trade agreements that remove 

unfair barriers to free trade. Polaris steadfastly supports these policies, which will ultimately 

benefit U.S. workers and consumers, as well as their international counterparts. 

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Polaris -Addendum for Parts for Hydraulic Fluid Pumps 

PUBLIC VERSION 

B. Polaris Is Affected by Section 301 Tariffs, But Some Foreign Competitors 

Are Not 

Current Section 30 I tariffs have resulted in [ ] higher costs for many components and 

parts used for final assembly in Polaris' U.S. factories. These Section 301 impacts are in 

addition to the increased costs of materials and components resulting from the Section 232 

steel/aluminum tariffs and the EU's 25% retaliatory tariffs on our Spirit Lake, Iowa-produced 

motorcycles and Canada's 10% retaliatory tariffs on our Elkhart, Indiana-produced boats. 

The unfortunate irony is that Polaris - a U.S.-based manufacturer and powersports market leader 

- is substantially affected by the Section 301 tariffs, while foreign-based competitors -

manufacturing outside the United States - are not. [ 

] 

C. Immediate Relief Is Needed 

The cost to Polaris of the currently-imposed tariffs and retaliatory tariffs is [ 

] 

[ 

] [ 

] 

Given the [ ] to Polaris' business, not shared by some of our foreign 

competitors, Polaris respectfully requests that USTR grant relief as soon as possible. 

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Polaris - Addendum for Parts for Hydraulic Fluid Pumps 

PUBLIC VERSION 

IV. Confidentiality Statement 

Consistent with USTR's Section 301 notice, Polaris 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. 

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