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 I 

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

2. This exclusion request is for product number SRM4437, a riveter machine (non-hydraulic press) made 

primarily of steel and used in the automotive sector in the manufacture and assembly of automotive 

components. The dimensions are 800x l 500x 1600mm and it weighs I ton (208V 30A). The product is 

shipped in a wooden crate with the product's part name - "Asset # SRM4437" clearly indicated with 

accompanying documents. This distinguishes this product from other imported products and facilitates 

the administration of this exclusion by CBP. 

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/ 

8462998000 

4. Requestor Information 

Requestor Name (Last, First): !Koursova, Larissa 

;::::==:::::::::==================================~ Organization Name: !Aisin World Corp. of America 

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

Requestor Representative: !David Hamill, PARTNER, Arent Fox LLP 

5. Requestor's relationship to the product: !... P_u_r_ch_a_s_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 Document 

VERSION 1 CONTINUED BELOW 
8. Is this product, or a comparable product, available from sources in the United States?: 

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

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: * 

20 17 Quantity: * 

2016 Quantity: * 

2015 Quantity: * 

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

provided in Section B of the Federal Register notice (note: text entered below can extend 

beyond the apparent size of this box). 

* This is a new product that has not historically been imported, but will be imported in the 

upcoming months due to previously planned production 

See attached for arguments in support of this exclusion request. 

VERSION 1 END 2 
i3.ISIN 

October 9, 2018 

VIA REGULATIONS.GOV 

The Honorable Robert E. Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

15300 Centennial Drive, Northville, Ml 48168 

Tel: (734) 453-5551 • Fax: (734) 453-4670 

AISIN GROUP' 

PUBLIC DOCUMENT 

Docket No. USTR-2018-0025 

Re: Request for Exclusion of Riveter Machine (non- hydraulic riveter) HTS 8462998000 from the 

Determination of Action Pursuant to Section 301 Tariffs 

Dear Ambassador Lighthizer: 

Aisin U.S.A. Mfg., Inc (AUM) respectfully submits this request for exclusion of Riveter Machines from 

the proposed determination of action pursuant to Section 301 of the Trade Act of 197 4. 1 

AVM has purchased and is in the process of purchasing the following part numbers of riveter machines 

through 2018 and the first half of 2019: SRM4440, SRM4437 and SRM4438. 

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

World Corp. of America headquarters are in Northville Michigan. In addition, our research and development 

capabilities can be found throughout the United States. 

AISIN AUM is located in Seymour, IN where over 1,000 employees are committed in producing high 

quality, functional, engine components for some of the largest automotive manufacturers in the United States. 

1 19 U.S.C. § 2411. 
i3.ISIN 15300 Centennial Drive, Northville, Ml 48168 

Tel: (734) 453-5551 • Fax: (734) 453-4670 

AISIN GROUP' 

Our approach has always been to follow a global strategy and establish our family of companies in the 

U.S.to support the U.S. domestic and U.S. import manufacturer base. We are constantly striving toward product 

improvement that will benefit consumers and its emphasis on environmental sustainability, community 

involvement and employee life balance, Aisin consistently lives up to its motto: "For a Better Tomorrow." 

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid to long range, our 

strategy in the United States is to squarely focus on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customers. For AISIN AUM, this is an investment for the future we gladly make. 

This exclusion request addresses riveter machines classified under HTSUS subheading 8462.99.8000 

which are currently subject to the 25% additional Section 301 tariff The riveter machine we cite in this 301 

exclusion request is purchased from China because it meets our engineering and product requirements. 

In accordance with the procedures released by the Office of the United States Trade Representative 

("USTR"),

2 AISIN AUM. provides the following information requested by the USTR in support of this request. 

I. Availability of the product outside of China 

Our U.S. customer specifications are exact and rigorous. AlSIN AUM invested a considerable amount 

of time and capital in working with our Chinese partner to ensure that these products were manufactured to our 

design requirements specifications. While an effort to find another manufacturer that would be able to produce 

this equipment to our customers' specifications is possible, it would take 6 months to a year to resource. 

2 Procedures To Consider Requests for Exclusion of Particular Products From the Determination of Action 

Pursuant to Section 301: China 's Acts, Policies, and Practices Related to Technology Transfer, Intellectual 

Property, and Innovation, 83 Fed. Reg. 32,181 (USTR July 11, 2018). 
i3.ISIN 15300 Centennial Drive, Northville, Ml 48168 

Tel: (734) 453-5551 • Fax: (734) 453-4670 

AISIN GROUP' 

For an automobile, the quality and consistency of materials, components, and equipment are of the 

utmost importance because they can impact the vehicles quality, safety, and performance. This is especially 

true for safety sensitive components such as doorframes and automotive seats. 

In short, this product from China has met the final approval of our automotive customer in the United 

States. The process to validate a new country source will require extensive testing to validate the product, both 

for our purposes as well as our OEM customers. More importantly, there is significant risk involved with the 

quality and delivery aspects of this revalidation in terms of production schedules. 

2. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requester or other US interests 

The riveter machines purchased by AISIN AUM that are included on the USTR's product list are key 

equipment of our automotive parts manufacturing and are imported to support domestic manufacturing 

operations and American jobs in the United States. The imposition of a 25% tariff on the riveter machines 

would cause severe economic harm to U.S. interests, including our employees, our customers, and consumers, 

who eventually will be paying higher prices for new vehicles. Specifically, any future business opportunities 

involving these products could be directly impacted by the price increase caused by the additional tariff. Our 

concern here is that the 25% tariff will impact the company's production costs, reducing profit margins and 

therefore minimizing any future R&D investments, in the long-run negatively impacting Aisin production 

strategy in the US. This will, in tum, adversely affect a broader spectrum of U.S. interests, including U.S. 

investments, and jobs. 

3. Whether the particular product is strategically important or related to "Made in China 2025" or other 

Chinese industrial programs 

The imposition of a 25% ad valorem duty on this riveter machine from China will not impact the 

Chinese intellectual property violations these seek to eliminate. Section 301 tariffs are aimed at specifically 

targeted products that have benefitted from the China's acts, policies, and practices detailed in the USTR's 
i3.ISIN 15300 Centennial Drive, Northville, Ml 48168 

Tel: (734) 453-5551 • Fax: (734) 453-4670 

AISIN GROUP' 

Section 301 Report. Made in China 2025 aims to promote their indigenous research and development 

capabilities. The riveter machines are not a new technology. 

We appreciate the Department's consideration of this exclusion request. Please contact the undersigned 

if you have any questions regarding this submission. 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted, 

Larissa V. Koursova 

Assistant General Manager, Purchasing 

Aisin World Corp. of America 

Phone + 1 734 582 7654 

Mobile + 1 248 756 9958 

lkoursova@aisinworld.com