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. 

I. Indicate whether the comment contains business confidential information (BCI), is a public

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

Pub ! lic Version ofBCI

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

CASE ASSY ; rect ang le with round ed ed ges with logo; used for REMOTE KEYL ESS ENTRY

UNIT - consist of p last ic case and acry lic emb lem with chrome surface. D imensions 34.00mm X

67.50mm X 7.00mm.

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 prod uct, see https:/ /hts.usitc.gov/

8538906000 

4. Requestor Information

Requestor Name (Last, First): 

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O rganization Name: !OMRO N Management Cent er of America, I nc. 

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

Requestor Representative: !

._D_ r_ink_e_r_B_id_ d_ _el _&_R_ e_at_h_L_L_P _______________ _ 

5. Requestor's relationship to the product:

... 

!O_ t _h er _ ___________________ _,

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.

Pub ! lic Version of BCI 

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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.

OMRON Management Center of America, Inc. submits this exclusion request on behalf of our business

unit. OMRON in the US is the only designer of this product and only supplier of this component.

CASE ASSY is a keyless entry fob witch case and is used only automotive purposes of containing a

remote-less lock/unlock signal transmitter, 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, the domestic automobile

industry, and ultimately the US consumer as a increase in price. 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, significant amounts of time, 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 ASSY in

question based solely on the product description. The following are draft CBP exclusion instructions:

"CASE ASSY; rectangle with rounded edges with [Acura] logo; used for REMOTE KEYLESS ENTRY

UNIT - consist of plastic case and acrylic emblem with chrome surface. Dimensions 34.00mm X

67.50mm X 7.00mm."

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