Polaris -Addendum for ATV Main Chassis Wire Harness 

PUBLIC VERSION 

0PDLARIS® 

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 A TV 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. 

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. [ 
Polaris -Addendum/or ATV Main Chassis Wire Harness 

PUBLIC VERSION 

II. Specific Exclusion Request for A TV Main Chassis Wire Harness 

Polaris' wire harnesses should be excluded from Section 301 tariffs because Polaris is in the 

process of re-sourcing the wire harnesses outside of China. [ 

] Since Polaris is 

actively shifting sourcing away from China- which is an Administration trade policy objective -

Polaris requests that its wire harnesses be excluded from the Section 301 tariffs during the resourcing process. 

A. Additional Information about Product Description (Question 2) 

A wiring harness is an organized set of wires, terminals and connectors that run throughout the 

entire vehicle and relay information and electric power, thereby playing a critical role in 

"connecting" a variety of components. Power and information travel through this network much 

like the circulatory and central nervous systems of the human body. Wiring harnesses consist of 

various wires bundled together, with each individual wire responsible for carrying the electric 

signals and energy used to power components of the vehicle, such as starting the engine and 

operating the lights. There are many different types of wire used in a wiring harness. Some 

varieties are more flexible, more heat resistant or more cold resistant, and others can be smaller 

for easier routing or larger for products requiring more current. The following is the product 

description for the ATV main chassis wire harness: 

All terrain vehicle main chassis wire harness including fairings, containing an assembly 

of individual electrical wires and connectors, which are bound together by straps, cable 

ties, sleeves, tape, conduit or weave in any combination, to transmit signals or electrical 

power to control module(s), sensors, lights, user controls and various electrical 

components, with lengths range from 2005-4265 (mm), widths ranging from 855-2147 

(mm), and average mass of 2706g. 

For informational purposes, the following is the picture of a wire harness: 

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Polaris - Addendum for ATV Main Chassis Wire Harness 

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

and Question 9 (Third Country Merchandise) 

Wire harness manufacturers exist in both the United States and in third countries. As shown 

below, Polaris is actively attempting to re-source the wire harnesses from suppliers outside of 

China. Polaris has developed a specific timeline to re-source the harnesses, which will take [ 

] . Given that Polaris is moving production outside of China, Polaris 

respectfully requests that USTR grant this exclusion to provide it the time necessary to allow 

Polaris to re-source the parts without having duties imposed. 

Due to the time it takes for supplier selection, capital equipment procurement, tooling set up, 

supplier validation, and launching full production, it will take almost [ ] to 

re-source one wire harness from China to North American suppliers. Currently, Polaris has 

approximately [ ] chassis and fairing harnesses that would need to be re-sourced. Polaris is in 

the beginning stages of quoting and setting up on site supplier visits. The following is the 

timeline for this re-sourcing project: 

Timeline: 

[ ] - Quoting 

[ ]- Onsite visits & supplier qualification 

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Polaris-Addendum/or ATV Main Chassis Wire Harness 

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[ 

[ 

[ 

[ 

[ 

[ 

ORV/ATV 

Task 

] - Final supplier selection and awards 

] - Define material, equipment, and tooling required 

] - Procure material, capital equipment, and install 

] - Test and start up equipment 

] - Assemble first off tool parts 

] - DVP&R (design verification, plan, and report) and validation 

Validation Timing by Product: 

Time Notes 

(weeks) 

Teardown Harness [ ] 

Review 

Build test vehicle [ ] 

Prep/ship test vehicle [ ] 

Field test [ ] general [ ] $[ 

on-road miles 

Return shipping of [ ] 

vehicle 

Teardown/Inspect [ ] 

vehicle 

Total [ ] [ 

] 

] - Production ramp up, run at rate audits, launch production demand 

] 

Total time spent to onboard new supplier and re-source parts= about [ ] 

Because Polaris is doing what USTR is requesting, namely moving production of the wire 

harnesses outside of China, Polaris respectfully requests that USTR provide Polaris with an 

exclusion for its wire harnesses so that it is not penalized while it is actively re-sourcing the 

product. 

C. Impact on Polaris (Question 11) 

In order to accomplish this re-sourcing, Polaris will incur significant costs. Polaris estimates that 

the cost to re-source the wire harnesses in question would be approximately$[ ] for 

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Polaris-Addendum for ATV Main Chassis Wire Harness 

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tooling and$[ ] for resources, including Polaris engineering, supplier quality, and 

purchasing. While Polaris is willingly incurring the costs to re-source away from a China 

supplier, it seeks to avoid the additional tariff-related costs that otherwise would be incurred 

during the re-sourcing process. 

Section III contains additional information concer~ing the impact on Polaris of the Section 301 

duties. 

D. Information about Intellectual Property and Made in China 2025 

Wire harnesses are not high tech products. Polaris has been using the same wire harness design 

and manufacturing methods that have been in place for the last 30 years. Harnesses contain the 

following: copper stranded wire of various gauges; splice joints; common connection systems 

which include male and female terminals, cables seals, terminal position assurance (as needed); 

harness covering comprised of tape and conduit; fasteners that attach the harness to the chassis. 

These are not products implicated by China's "Made in China 2025" policies. Harnesses are a 

low skill labor, low IP aspect of manufacturing. Most if not all major industrialized countries are 

producing harnesses and there is not any specific technology being developed in China that will 

advance the use of harnesses or eliminate the use of harnesses in our products. 

E. Draft CBP Language 

Polaris believes that CBP can easily exclude the wire harnesses in question based solely on the 

product description. The following are draft CBP exclusion instructions: 

Excluded from the Section 301 additional duties are all terrain vehicle (A TV) main 

chassis wire harness including fairings, containing an assembly of individual electrical 

wires and connectors, which are bound together by straps, cable ties, sleeves, tape, 

conduit or weave in any combination, to transmit signals or electrical power to control 

module(s), sensors, lights, user controls and various electrical components, with lengths 

range from 2005-4265 (mm), widths ranging from 855-2147 (mm), and average mass of 

2706g. 

This information will be contained on the invoice from the supplier listing the fact that it is a 

A TV main chassis wire harness with the above dimensions. 

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 ATV Main Chassis Wire Harness 

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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 for ATV Main Chassis Wire Harness 

PUBLIC VERSION 

] [ 

] 

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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