Polaris -Addendum for Plastic Injection Mold Exclusion 

PUBLIC VERSION 

QPDLRRIS® 

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. 

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Polaris - Addendum for Plastic Injection Mold Exclusion 

PUBLIC VERSION 

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. [ 

] 

II. Specific Exclusion Request for Plastic Injection Molds 

Polaris' imported plastic injection molds should be excluded from Section 301 tariffs because, 

[ 

Polaris uses the imported molds subject to this exclusion request in the production of 

motorcycles, snowmobiles, A TVs, and Side-by-Sides. All imported molds will be transported to 

a Polaris facility in the United States or another supplier located in the United States to mold 

vehicle parts in the United States. The following are the internal model names and vehicle types 

for which Polaris uses the molds to produce parts in the United States: 

[ 

] 

A. Additional Information about Product Description (Question 2) 

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Polaris -Addendum for Plastic Injection Mold Exclusion 

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A plastic injection mold is a shape-forming process in which molten plastic is injected into steel 

or aluminum molds (shaped like the end product) and squeezed under high pressure. Plastic 

parts used in the manufacture of Polaris vehicles are made from these molds. Exhibit 1 contains 

diagrams and pictures of a sample Polaris plastic injection mold imported from China. 

B. Additional Information about Question 8 (Comparable U.S. Merchandise) 

and Question 9 (Third Country Merchandise) 

Although molds are available in the United States, they are not produced in adequate supply for 

the less complex parts that Polaris makes and not in the lead times that Polaris requires. Polaris 

often sends out RFQs for its mold requirements. In fact, [ 

]. 

[ 

] 

As stated above, in [ 

] 

C. Additional Information about Question 11 (Final Product or Input into 

Production of Final Product). 

Many of the plastic injection molds [ 

], Polaris respectfully requests that 

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Polaris - Addendum for Plastic Injection Mold Exclusion 

PUBLIC VERSION 

USTR exclude them from the Section 30 I tariffs. If it does not receive an exclusion, Polaris 

[ 

D. Additional Information about Intellectual Property and Made in China 2025 

Polaris owns all of the intellectual property concerning the design of the mold. Polaris provides 

the Chinese suppliers with all of the mold specifications and CAD files for part design. Polaris 

was not required to provide IP or other technology rights to any Chinese companies. The vehicle 

parts produced from the molds are exclusive to Polaris, who created and controls all drawings 

and models provided to vendors. These molds are considered to be routine technology and 

would not be covered by the Made in China 2025 . 

E. Draft CBP Language 

Polaris believes that CBP can easily exclude the molds in question based solely on the product 

description. The following are draft CBP exclusion instructions: 

Excluded from the Section 301 tariffs are plastic injection molds with preconfigured features 

necessary for the functioning of the plastic injection mold (such as plastic part geometry in 

cavity and core plates, ejector box geometry, magnetic attachment geometry, gating, cavity 

venting, and drilled holes, slots, and bushings, to accommodate the various guide pins and 

dowels), regardless of the number of mold plates, and regardless of the type or grade of steel 

or aluminum ( or combination thereof) from which it is produced, with the following 

dimensions of the platens: 

• Length ranging from 15.0 inches to 103.0 inches; 

• Width ranging from 15.0 to 167.0 inches; and 

• Thickness ranging from 10.0 to 144.0 inches. 

III. 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, [ ] 

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Polaris -Addendum for Plastic Injection Mold Exclusion 

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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; Anaheim, 

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. 

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

Are Not 

Current Section 301 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 [ 

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Polaris -Addendum/or Plastic Injection Mold Exclusion 

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] 

] [ 

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

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

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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