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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 version of BCI

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

 Please see attached supporting letter.

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/

 8419390180

4. Requestor Information

Requestor Name (Last, First): Aliasso, Joe

Organization Name: IMA Life North America, Inc.

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

Requestor Representative: Jon P. Yormick, Phillips Lytle, LLP

5. Requestor’s relationship to the product: Importer

6. Does this submission in regulations.gov include additional attachments?

 Yes

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 version of BCI
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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.)

 No. Please see attached supporting letter.

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. Please see attached supporting letter.

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: [ ] 2017 Quantity: [ ]

2016 Value: [ ] 2016 Quantity: [ ]

2015 Value: [ ] 2015 Quantity: [ ]

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

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

 [ ] % 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.

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).

 Please see attached supporting letter.