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 Document 

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

Item Name: Two Station Plugger and Sorter 

Dimensions: 80" x 43" x 60"; Weight: 200kg 

Power Source: 220v; Material Composition: Stainless Steel construction 

Capabilities: The Rotary Plugging Machine is an entirely custom machine to place plugs/bungs into our 

16 oz squeeze bottles. The plug/bung is inserted after the bottle is filled. This allows the bottle to 

function as intended. The plugger will feed and press bungs/plugs at a rate of 30 bottles per minute. 

3. 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/ 

8422309140 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

Benson, Richard 

Lubrication Specialties, Inc. 

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

Requestor Representative: 

5. Requestor's relationship to the product: Purchaser 

6. Does this submission in regulations.govinclude additional attachments? 

IYES 

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 Document 

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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). 

IN° 

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). 

NO 

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: 0 2017 Quantity: 0 

2016 Value: 0 2016 Quantity: 0 

2015 Value: 0 2015 Quantity: 0 

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? 

FINAL PRODUCT Li 

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

0 % 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: 

% 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). 

The Two Station Plugger and Sorter herein described is part of a larger bottling line, imported into the 

U.S. in order to increase the number of manufacturing jobs available to American workers. As we will 

be using the Two Station Plugger Sorter for a very uniquely designed 16oz squeeze bottle, with handle 

which is 7" x 2.5" x 4.5" and each part of the line must be properly synchronized with the others to 

achieve maximum efficiency, each of its parts had to be custom fit to the whole. The Two Station 

Plugger Sorter is the most unique piece of equipment we have ever purchased, as it is very rare to find a 

squeeze bottle similar to ours (See attached). We know of no one who has anything remotely similar to 

the Two Station Plugger and Sorter available for purchase. 

Lubrication Specialties Inc., is a small business comitted to growing the local and American economies. 

When we made the purchase order for the Two Station Plugger Sorter, as part of the purchase of an 

entire bottling line, there were no ready-made bottling lines fitting our needs available from a U.S. or 

third-country source. The line had to be custom built. 

By the time the tariff was imposed, production had already been substantially completed and the Two 

Station Plugger and Sorter only had to be shipped. Reneging on the deal would not only have harmed 

LSPs reputation, but would have damaged the United States reputation at home and abroad. Moreover, 

it would have cost American workers time on the job, as we would have had to wait indefmately for a 

replacement Plugger to be engineered and manufactured in the U.S. 

As the aggreggate tariffs on the line imposes significant economic harm on our small company, there are 

no immediately available replacements manufactured in America or a third country, and the Two Station 

Plugger and Sorter is not listed on the China 2025 list, and excluding the components of this bottling line 

from the tariffs will help bring manufacturing jobs back to America, we respectfully request the Two 

Station Plugger and Sorter be excluded from the tariff. 

The information provided is complete and correct to the best of my knowledge. 

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