Pick Five Imports, Inc. dba Maxi-Matic, USA

18401 E. Arenth Ave.

City of Industry, CA.91748

(626) 912-9877

October 8, 2018

BY ELECTRONIC SUBMISSION

The Honorable Robert E. Lighthizer 

United States Trade Representative 

600 17th Street, NW

Washington, DC 20508

Re: Section 301 Request for Product Exclusion. Docket USTR-2018-0025: Meat 

Grinders, HTS 84385000900

Dear Ambassador Lighthizer:

Pick Five Imports, Inc. (“Maxi-Matic”) is a small privately owned minority business 

based in City of Industry, CA. Maxi-Matic imports a wide variety of small electric kitchen 

appliances under the Elite brands in addition to supporting private label brands for many retailers 

throughout the United States. In total Maxi-Matic employs over 75 people in California. 

Pursuant to the July 11, 2018 Federal Register notice,1 Maxi-Matic respectfully seeks an 

exclusion for its meat grinder, which is entered under U.S. Harmonized Tariff System (“HTS”) 

category

1 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. 32828 (July 11, 2018).
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84385000900. That HTS category is currently subject to tariffs of 10 percent pursuant to the 

Notice of Action published on June 20, 2018.2

Maxi-Matic’s products are designed to support today’s busy lifestyle by making 

preparation time faster and more efficient allowing families and friends more quality time in 

order to create memory-making moments. Our products include blenders, water kettles, indoor 

grills, rice cookers, deep fryers slow cookers, toaster ovens, air fryers, hand mixers, electric 

knifes, food choppers, ice cream makers, popcorn makers, ice cream makers and ice makers.

Product Description

Maxi-Matic is seeking exclusion for its meat grinder which is a specialized kitchen 

appliance that will allow families to make meat preparation more efficient and cost effective. 

This has become a growing category for the last 10 years which saves families money by not 

utilizing commercial suppliers for meat preparation for small amounts which can be costly. 

Specifically, the product is rated only for household use and is a 550 watt grinder for 

very small processing. Average dimensions for the meat grinder are L: 13.5” x W: 6.25” x H: 

10” and it weighs 8.5 lbs. It consists of a steel housing and has a manual control, in addition to 

various disks used to prepare various types of sausages. A photograph of the meat grinder is 

provided at Exhibit 1.

2 Notice of Action and Request for Public Comment Concerning Proposed Determination of Action Pursuant to 

Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and 

Innovation, 83 Fed. Reg. 28,710 (June 20, 2018
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Negative Impact of Tariffs

The 10% tariff on products of China covered in HTS 84385000900 will severely impact 

Matic-Matic and its employees located in California. Meat Grinders are one of Maxi-Matic’s 

most popular niche products and have already received orders in excess of $[ ] from retail 

vendors for their brick-and-mortar and e- commerce sales channels. The meat grinder is not 

produced in the United States or in any third countries and would take well over a year to 

establish any type of new production as an alternative production resource

The tariff would also negatively impacts retailers that sell meat grinders, particularly 

brick-and-mortar retailers who rely on customer foot traffic for sales. The meat grinder was

designed to be an affordable appliance providing a cost effective alternative to commercial 

meat processing for small families. A 10 percent tariff would force Maxi-Matic and its retail 

customers, such as Amazon, HSN and QVC to name a few, to raise prices resulting in lost 

sales and higher prices with fewer affordable options.

The Meat Grinder is Not Strategically Important to Chinese Industrial Programs

Maxi-Matic’s meat grinder is not the type of advanced, manufactured consumer good 

identified in the Chinese government’s “Made in 2025” program. The meat grinder is a machine 

that is an inexpensive countertop appliance with a suggested retail price of $79.99. The meat 

grinder prepares various meats. It does not incorporate any advanced technologies that would 

raise concerns about technology transfers.
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Small household appliances such as meat grinders, and other Maxi-Matic products, are 

not the target of the “Made in China 2025” program or any other Chinese industrial policy.

Those Chinese policies focus on high-tech products such as new energy vehicles, robots and 

renewable energy products. The meat grinder does not incorporate advanced technology that is 

of strategic interest to China. Therefore, there can be no concerns about technology transfer as it 

does not contain industrial significant technology. The application of the duties to Maxi-Matic’s 

meat grinder is not consistent with the stated purpose of the tariffs, which is to impose duties on 

“goods imported from China containing industrially significant technology, including those 

related to the ‘Made in China 2025’ program.”

Tariffs on meat grinders will not further the objectives of the Section 301 investigation 

to obtain reforms of China’s unfair industrial policies. As noted above, the product is not a 

target of the Chinese government policies. Imposing tariffs will have no impact on the success 

of those policies. Further, imposition of a tariff on this product is unlikely to cause or inspire 

the Government of China to reform its unfair trade policies. Meat grinders that Maxi-Matic

imports are not made by any U.S. producer and are not readily available from third-country 

suppliers. The additional cost arising from the tariffs will impact American Suppliers, US 

Retailers and American consumers and not Chinese companies, 

* * *

Maxi-Matic requests confidential treatment for information designated as business 

confidential in this submission. Such information consists of information that would not 

customarily be released to the public, the disclosure of which would endanger trade secrets or
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profitability. Release of this information would cause irreparable harm to the submitter. 

Release of this information would cause irreparable harm to the submitter. Business 

confidential information is indicated in the comments above and in the product exclusion 

request form via single brackets ("[ ]"). Release of this information would cause irreparable 

harm to the submitter. A public version of these comments and a public version of the product 

exclusion request form are also being filed with all confidential information redacted.

I, Sandy Liu, CEO of Maxi-Matic, certify that the information provided in the comments 

above and in the product exclusion request form is complete and correct to the best of my 

knowledge. If you have any questions or require additional information, please do not hesitate to 

contact the undersigned.

Regards,

Sandy Liu, CEO

Maxi-Matic, USA