PUBLIC

Request for Exclusion of Particular Products from the 

Determination of Action Pursuant to section 301: China’s Acts, 

Policies, and Practices Related to Technology Transfer

“Enforcement/Section 301 investigations”

HTSUS 8416.90.0000-P - NTFB Combustion Equipment USA Inc.

Docket number: USTR-2018-0025.

www.regulations.gov - supporting documents

1. Identification of the particular product in terms of the physical characteristics 

 Burner type pistol and windbox

 Application (applicable model); as a necessary accessory for the burner, when 

burning, the fuel enters the furnace through the machine head for combustion. The fuel 

and air are pre-mixed in the windbox before entering the machine head. After mixing, the 

fuel enters the burner head through the windbox (for NTFB burners)

 Material Composition: Metal parts

 Color: Gray and Purple

 Assembly: Bolts and welding

 Burner Brand; NTFB / Models; GS11-01-I-2, GS11-01-I-4, GS11-01-I-6, GS11-01-

I-10, GS-11-1110-C-C1, GS-11- 1110-C-E1, GS-11-1110-C-F1
2. The 10 digit subheading of the HTSUS most applicable to the particular 

product requested for exclusion.

USTR 8416.90.0000 - Parts for furnace burners.

3. Requestors also may submit information on the ability of U.S. Customs and 

Border Protection to administer the exclusion.

Customs and Border Protection should have the ability to administer the exclusion 

here requested. The merchandise is transported in two transoceanic containers with 

all due paperwork up to date. Contact information for the receiving office and contact 

person are included.

4. Is the particular product available only from China?

Are there comparable products available from sources in the United States 

and/or in third countries?

Comparable products to the burner part being exported are available in many 

countries including U.S. and China. Importing these parts from another country or 

manufacturing in the U.S. makes the final product no price competitive and our 

business will not survive. 

The final product will be exported to China with NO TECHNOLOGY strategically 

important or related to “Made in China 2025”.

5. Is the imposition of additional duties on the particular product would cause 

severe economic harm to the requestor or other U.S. interests?

Yes. The imposition of additional duties on the burner parts would cause severe 

economic harm to our NTFB Combustion Equipment US Inc. and to the U.S export to 

China. 

NTFB Combustion US aggressively compete with international burner companies for 

the Chinese market. It is the reason why our business is susceptible to a small profit 

margin per unit. A 25% tariff increase on the burner parts will completely erode our 

profit while opening opportunities for NO U.S Companies to have the advantage over 

U.S Companies in the international market. 

6. Is the particular product strategically important or related to “Made in China 

2025” or other Chinese industrial programs?
No. The burner parts in question are not strategically important or related to “Made in 

China 2025” or other Chinese industrial programs. The equipment in question is an

essential part of the steam boiler system, generally used for heating.

All the burner parts received will be part of a full burner assembly sold to Chinese 

companies. Furthermore, the technology in this equipment is in its internal design;

wish is already in the parts being exported from China. 

The scope of U.S. work returning to China is final assembling, any additional U.S 

component required for the safe working conditions on specific project environment, 

and a complete quality control check of the final product. 

Please note that many other countries like Korea, Japan, Italy, Germany, including 

China are capable of doing similar work. Imposing 25% to the parts imported to the 

U.S from China in this particular product will eliminate any competitive advantage we 

could have to compete in the international market.

The submitter certifies that the information provided is complete and correct to 

the best of his or her knowledge.

Edison Guerra

NTFB Combustion Equipment USA Inc.

edisong@ntfb.com

p.510.443.0066

2875 Lakeview Ct. Fremont, CA 94538 – USA