SYNTRON MATERIAL HANDLING

8431390010 SMH 5118-123-001. Exclusion Letter P.docx

Sunday, October7, 2018

Ambassador Robert Lighthizer

U.S. trade Representative

Office of the United States Trade Representative

600 17th Street NW

Washington, DC 20006

Re: USTR-2018-0025 - Procedures to Consider Requests for Exclusion of Particular Products from the 

Determination of Action Pursuant to Section 301: This part is a fabricated steel bracket made 

from 1⁄4” mild steel plate which is used to support to return rollers on a belt conveyor. The 

bracket is designed to fit a 4” channel support structure which makes it unique to this 

product. Syntron Part number 5118-123-001.B 

BRACKET, RIG. FR.RET 14.75DP 4” CHANNEL

(HTS# 8431.39.0010)

Dear Ambassador Lighthizer:

 Syntron Material Handling (SMH) provides material handling solutions for conveying, 

feeding, elevating, vibratory flow aids and mining controls of bulk product. As a leader of 

innovative material handling solutions we offer efficient and cost-effective solutions to improve 

and enhance the technology manufacturing business customers are already using. 

 Industries we serve include food handling, ports and terminals, aggregates, cement, glass 

mining, pulp and paper, power generation and trona-potash-salt. 

 Our products include vibrating conveyors, belt conveyor idlers, screw conveyors, bucket 

elevators, underground mining, heavy duty and light industry feeders.

 

SMH is located in Saltillo, Northeast Mississippi. Saltillo has an estimated population of 5000. 

Our 300,000 square foot facility was built in 1974 and it houses Syntron Material Handling and 

our Corporate Office. SMH currently employs 229 full-time team members.

Additionally, there is a Syntron Material Handling Solutions facility in Changshu, China. This 

location was established in 2006 and employs 23 team members.

Mission Statement

Syntron material Handling is a customer focused industry leader with a reputation for providing 

innovative engineering, high-performance products, and superior customer service.

Annual Quantity & Value

2017 Value: [BCI] 2017 Quantity: [BCI]

2016 Value: [BCI] 2016 Quantity: [BCI]

2015 Value: [BCI] 2015 Quantity: [BCI]
SYNTRON MATERIAL HANDLING

8431390010 SMH 5118-123-001. Exclusion Letter P.docx

RATIONALE FOR REQUESTED EXCLUSION

This bracket is a component part and not a final product.

11. Is the Chinese-origin product of concern sold as a final product or an input used in

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

[BCI]%] 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: 

[BCI]%] of the total cost of producing the final product(s) the Chinese-origin input accounts 

for.

[BCI]%] of your total gross sales in 2017 that sales of the final product(s) incorporating the 

input accounted for.

Particular product available only from China

SMH sourced from China due to cost competitiveness. This required SMH to find an 

overseas supplier to help support for the irregular demand for this bracket. Tooling cost in 

the US would be prohibitive for a relatively low volume product such as this bracket.

Economic Impact

SMH understands that the purpose of the Section 301 tariffs is to eliminate unfair Chinese 

trade practices relating to the misappropriation of United States intellectual property and 

technology. The imposition of these tariffs is intended to be practicable and effective to 

obtain the elimination of acts, policies, and practices viewed as detrimental. Imposing 

tariffs on these products would negatively affect this company as well as SMH customers. 

SMH currently employs 229 team members in our Saltillo, MS, location. SMH employees

represent approximately 9% of Saltillo, Mississippi workforce. Additional costs in tariffs 

will lead to reduced competitiveness and a drop in demand, ultimately resulting in loss of 

employment and marginal profitability.

Made in China 2025

Placing tariffs on bracket component would not benefit U.S. industry, nor would it further 

the USTR’s stated goals underlying the Section 301 investigation. According to the 

USTR’s Section 301 Investigation findings, China’s “Made in China 2025” industrial policy 

is centered on promoting ten strategic sectors of high-technology industries. Neither the 

bracket nor the final article the bracket is incorporated into is among those categories.
SYNTRON MATERIAL HANDLING

8431390010 SMH 5118-123-001. Exclusion Letter P.docx

Made in China 2025 (cont')

The Chinese government has not employed any tactics to intervene in or regulate SMH’s 

operations in China. It has not attempted to use discretionary administrative licensing and 

approval processes, foreign equity limitations, or foreign ownership restrictions to require 

or pressure SMH to transfer technology. SMH’s control over its intellectual property and 

technology in China has not been undermined, and the Chinese government has not 

directed or facilitated investment in or acquisition of SMH’s assets or intellectual property. 

SMH is similarly unaware of any data breaches or attacks on any SMH facilities in China. 

The Chinese government does not consider SMH’s this bracket or the final article the 

bracket is incorporated into to be an area of strategic concern for its industrial policies. 

Imposing additional tariffs on such an input component would only harm American 

interests and would not have a material effect on China’s acts, policies and practices used 

to acquire foreign technology or that the USTR has found to be unreasonable or 

discriminatory.

Impact to SMH Workforce

 Should we have to raise costs of products to recoup this additional tariff expense, which 

we have begun to do, and that could reduce our competitiveness in the market and 

ultimately impact retention of our current workforce of 229 people in Saltillo, MS.

SMH is unaware of any potential issues that would affect the ability of US CBP to 

administer subject exclusion. CBP should be able to easily identify the products based on 

HTSUS code and standard information provided.

As such, we respectfully request exclusion from Section 301 for our product, 5118-123-

001.B, classified under HTS# 8431.39.0010, that is produced and sourced from China.

Additional Supporting Information

PRODUCT PHOTO 
SYNTRON MATERIAL HANDLING

8431390010 SMH 5118-123-001. Exclusion Letter P.docx

PRODUCT TECHNICAL DATA