Main Office • 47677 Galleon Drive • Plymouth, Michigan 48170 • (734) 446-2200 • Fax (734) 446-2262

Calexico Branch • 1777 Stergios Road, Building “B” Suites 9&10 • Calexico, California 92231 • (734) 446-2500 • Fax (734) 446-2599

Mail Address • P.O. Box 2778 • Calexico, CA. 92232.

October 8, 2018

The Honorable Robert Lighthizer

United States Trade Representative

Office of the United States Trade Representative

600 17th ST. NW

Washington, D.C. 20508

Re: USTR-2018-0025 – 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 FR 

32181).

Dear Ambassador Lighthizer:

This letter is being submitted in support of the American Furukawa, Inc., (“AFI” or “the 

Company”) application for exclusion from the Section 301 tariffs of AFI’s Lead Battery 

Status Detection Sensor (“Detection Sensor”), falling under tariff code 9030.33.3800 of the 

Harmonized Tariff Schedule of the United States (“HTSUS”). AFI imports these Detection 

Sensors as an electrical auto component for light vehicles. This letter is intended to address 

the requirements stipulated in Part B of the Federal Register Notice detailing the process for 

requesting a product exclusion from the Section 301 tariffs. (83 Fed. Reg. 133 (July 11, 

2018)).

This document and the form associated, and the information is public.

This exclusion request is in reference to HTSUS code 9030.33.3800, which provides for

oscilloscopes, spectrum analyzers and other instruments and apparatus for 

measuring or checking electrical quantities, excluding meters of heading 

9028; instruments and apparatus for measuring or detecting alpha, beta, 

gamma, X-ray, cosmic or other ionizing radiations; parts and accessories 

thereof; Other, without a recording device:; Other; 

Products under this HTSUS code are currently subject to additional 25% tariffs as of 

July 6, 2018 in accordance with the Section 301 tariff for products included on List 1.

As discussed below, subjecting AFI’s Detection Sensor to the tariffs would cause severe 

economic harm to a U.S. company that is a supplier of these crucial parts to several 

automotive industry original equipment manufacturers (“OEMs”).

I. AFI’s Background
Main Office • 47677 Galleon Drive • Plymouth, Michigan 48170 • (734) 446-2200 • Fax (734) 446-2262

Calexico Branch • 1777 Stergios Road, Building “B” Suites 9&10 • Calexico, California 92231 • (734) 446-2500 • Fax (734) 446-2599

Mail Address • P.O. Box 2778 • Calexico, CA. 92232.

AFI is a part of Furukawa Electric Group and is a supplier of world-class products for 

customers in the automotive, electronics, infrastructure and medical industries. AFI is 

headquartered in Plymouth, Michigan and employs eighty-seven employees throughout

the United States in a variety of roles.

II. Product Background

The Detection Sensor was developed by Furukawa Electric, Co. (Japan) and is an electrical 

auto component for light vehicles. Manufacturing and sales started in 2017.

Year 2017 sales value in, U$736,218.60 Dlls., sales quantity: 99,489 pieces.

Year 2016 & year 2015, no sales in the United States.

The product is Lead Battery Status Detection Sensor (Length 2.36 inches, Width 1.98 inches, 

Height 1.61 inches, Weight 0.147 pounds). 

This product consists of polybutylene, terephthalate, case & cover, copper terminals & shunt 

resistance, and steel terminal holder & nut & screw. And glass epoxy printed circuit board is 

installed inside. 

Lead battery status detection sensors are attached to lead batteries, as its primary functions is

to monitor battery charging / discharging current, voltage and temperature with high precision

and provide battery information that is important for vehicle power source management. By 

doing so, they contribute to improved fuel efficiency and reduction of CO2 emissions through 

the prevention of battery rundown, charging control and idling stops. It is constructed out of 

unique detection algorithms based on a wealth of knowledge and experience of the lead 

batteries used in automobiles to realize highly precise battery status detection.

Please refer to below images, see how this product is attached to the battery of a vehicle.

III. China’s role as a supplier of Detection Sensors:

 

 Sensor attached to the battery. Sensor.
Main Office • 47677 Galleon Drive • Plymouth, Michigan 48170 • (734) 446-2200 • Fax (734) 446-2262

Calexico Branch • 1777 Stergios Road, Building “B” Suites 9&10 • Calexico, California 92231 • (734) 446-2500 • Fax (734) 446-2599

Mail Address • P.O. Box 2778 • Calexico, CA. 92232.

Currently, there are no other sourcing options outside of China that make financial sense and 

would not disrupt the supply to the U.S. market of this critical component. This is a product 

recently developed by Furukawa Electric, Co. (Japan) and allocated for manufacture to its 

affiliate Furukawa Electric Shenzhen, Co. Ltd. (China).

We have examined the effort required to supply this product from outside of China, but there 

are significant challenges to resourcing. As of today, it is impossible to obtain any quantities

of the Detection Sensor from outside China; there is no other Furukawa company manufacturing 

this product. The Detection Sensor is only available from China in the quality and quantity 

suitable for the U.S market. 

Based on our assessments, there are no domestic sources capable of producing the products in 

a manner that meets our required specifications, quantity demands, and safety standards.

In order to remain competitive, we also continuously explore whether suitable Detection 

Sensors are available from foreign suppliers located outside of China. Our assessments have 

indicated that foreign manufacturers located outside of China may exist; however, the 

complexity of the product and the time required to establish a new production facility make this 

kind of foreign sourcing impossible in the short term and significantly more expensive in the 

long term. Identifying new suppliers who could provide the necessary parts in the volume and 

quality required would further increase lead times and costs. In order to avoid additional 

expenses, we would anticipate needing to make significant and costly changes to our company’s 

logistics and procurement channels. 

In addition to the complexity of the Detection Sensor itself, we must also ensure that any new 

manufacturing location would have a workforce that is sufficiently trained and has adequate 

resources and infrastructure. Based on our previous experiences, we estimate that setting up a

new production facility outside of China would require several years to establish and a 

significant amount of capital. 

In sum, the Detection Sensors cannot be produced domestically due to a lack of available 

quality and quantity. 

IV. Imposition of the Duties on Lead Battery Status Detection Sensor would Cause Severe 

Economic Harm to American Furukawa, Inc. and U.S. Interests

The imposition of additional tariffs on this product would cause severe economic harm. 

Foreseen economic losses will amount to $700,000.00 USD per year.

Absorbing the cost would significantly decrease our operating profits and may likely require 

us to reduce our current staffing levels in the United States. Alternatively, passing the cost of 

the tariff on to the customer would result in a significant loss of market share as customers 

move to our foreign competitors, including companies based in China. Similarly, a significant 

loss of customer orders would likely result in a reduction to our U.S. workforce. Therefore, 
Main Office • 47677 Galleon Drive • Plymouth, Michigan 48170 • (734) 446-2200 • Fax (734) 446-2262

Calexico Branch • 1777 Stergios Road, Building “B” Suites 9&10 • Calexico, California 92231 • (734) 446-2500 • Fax (734) 446-2599

Mail Address • P.O. Box 2778 • Calexico, CA. 92232.

this outcome of raising prices would result in harm to both U.S. businesses and consumers, as 

well as AFI.

V. Lead Battery Status Detection Sensor is not Strategically Important to the “Made in 

China 2025” Industrial Program

AFI does not believe that Detection Sensors are related to the “Made in China 2025” program 

or other Chinese industrial programs, which are intended to “transform China into an 

advanced manufacturing leader.”1 

Furukawa Electric, Co. was not forced to enter into joint ventures with Chinese firms under 

terms that require the sharing of sensitive intellectual property and/or advanced technological 

know-how. The Detection Sensor is not manufactured by a Chinese state-backed company,

and investment does not come from funds backed by the government of China.

VI. Conclusion

The Detection Sensor is unrelated to the “Made in China 2025” initiative. It is manufactured 

in a Furukawa affiliate company. It is a recently designed product which is only manufactured 

in China with equipment shared to satisfy China’s market demand as well as North America’s

market demand.

The tariffs will cause severe economic harm to AFI, likely resulting in a reduction to our U.S. 

workforce. Passing costs of the tariffs on to customers will also cause harm to businesses and 

individual consumers in the United States.

The possibility for relocating the China manufacturing site is not feasible in the near term 

since equipment is shared to manufacture the Detection Sensor for China and North America.

Splitting operations is not financially possible as of today.

As such, AFI respectfully asks for exclusion of Detection Sensors under HTSUS code

9030.33.3800. 

I, Katsumasa Sekiguchi, certify that the information provided is complete and correct to the 

best of my knowledge.

Sincerely,

Katsumasa Sekiguchi, President 

ksekiguchi@americanfurukawa.com

Mobile: 734-589-7558

Office Desk: 734-446-2221

 

1 Made in China 2025: Global Ambitions Built on Local Protections, The U.S. Chamber of Commerce, 2017, 6.