PUBLIC VERSION
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20.0

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0.05

PUBLIC VERSION
Consistent with USTR's Section 301 notice, OMRON Management Center of America, Inc. 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.

OMRON in the US is the only designer of this product and only supplier of this component.

POWER WINDOW SWITCH is a molded plastic switch containing

electrical switches, and is used only for automotive purposes as a switch to move the windows open or

closed. It is only used for further assembly of components which go into domestic

automobile production, which is specified by auto manufacturer.

This product is not a target of the US Administration's 301 investigation regarding Intellectual Property

concerns. This is not a concern to IP transfer and impressment. This product contains no IP of interest

related to autonomous vehicle production.

The tariff action ultimately poses a risk of significant damage to OMRON, the domestic

automobile industry, and ultimately the US consumer as an increase in price. Like in the case of similar

approvals for vehicle components at the HTS level, OMRON views this product in the same manner.

Immediate movement of production to a US manufacturer or another country would pose significant

re-tooling costs , significant amounts of time , and approvals pertaining

to consumer automobile safety standards are costly and would take a significant amount of time to

obtain.

OMRON Management Center of America, Inc. believes that CBP can easily exclude the POWER

WINDOW SWITCH in question based solely on the product description. The following are draft CBP

exclusion instructions:

"POWER WINDOW SWITCH flat rectangular assembly with six switches: two "u" shaped on the

bottom row, two "u" shaped in the middle row, and two toggle switches oriented with the length of the

assembly "Plastic case with knob assemblies used for POWER WINDOW SWITCH (4 DR

master).Consist: - 1 Plastic case- 4 window knobs and 1 door lockout knob with 5 spring and 5 plungers

to drive the knob movement;- 1 window lockout knob assembly consist of 2 plastic plates and 1 plastic

window lockout knob;- 1 lockout assembly consists of 1 case, 2 springs, 1 pin and 1 plastic plunger.- 2

plastic light guides for light transmission- 2 screws. Case: 137.1mm x 64mm x37.2mm Knob (DR A1

S): 28.73 mm x 20.08 mm x 28.26 mm Knob (A1 S): 28.73 mm x 20.08 mm x 28.26 mm Knob (M S):

28.89 mm x20.08mm x28.26mm Knob (D/L L): 28.8mm x16mm x35.5mm Knob (W/L): 25.7mm

x20mm x20.16 mm"

This information will be contained on the invoice from the supplier

PUBLIC VERSION