FTDS Purchasing Americas

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TI Automotive

2020 Taylor Road

Auburn Hills, Michigan 48326

Telephone: (248) 296-8831

Fax: (248) 377-9076

October 8, 2018

VIA ELECTRONIC SUBMISSION

WWW.REGULATIONS.GOV

The Honorable Robert E Lighthizer

United States Trade Representative 

Office of the U.S. Trade Representative

600 17th Street, NW

Washington, DC 20508

Re: Request for Section 301 Exclusion (Docket Number USTR-2018-0025)

Armatures used in Automotive Fuel Pumps classified in HTS 8413.91.9010

Dear Mr. Lighthizer

TI Group Automotive Systems, LLC (TI Automotive or the Company) respectfully submits the following exclusion request 

in response to the notice of the United States Trade Representative (“USTR”) regarding the actions in connection with 

Section 301 China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. 

TI Automotive requests the exclusion of armatures used on fuel pumps for internal combustion piston engines classified 

under HTS 8413.91.9010

Company & Product Overview

TI Group Automotive Systems, LLC is headquartered is located in Auburn Hills, Michigan and is a tier one supplier to the 

automotive industry specializing in Fluid Carrying Technology. TI Automotive imports certain components from China

used in the production of Fuel Pumps and Fuel Modules assembled in the United States at our plants located in Caro, 

Michigan and Greeneville, Tennessee.

Detailed Product Description

Armature – a key component of the Electric Fuel Injection Pump. The armature is comprised of a commutator of unique 

conductive material and design, pressed on top of stacked metal plates with a bearing shaft protruding from both 

ends. The metal plates have segmented groupings of wire wound in a unique pattern terminated to the 

commutator. When the armature is exposed to a magnetic field and DC voltage passes from the commutator through the 

wires, the armature will rotate providing the spinning motion for the pumping elements of the fuel pump. The armatures 

employ unique electro-graphitic materials & tolerances, meeting specific motor performance characteristics that are 

“safety critical” for automotive fuel systems product for OEM production, OEM service and Aftermarket applications

Lack of Production in the United States

There is no production of custom- engineered armatures for fuel pump electric motor applications in the United States. 

The technology, engineering and product designs provided by TI Automotive are from our Engineering Group located in 

Auburn Hills, Michigan. Our designs are engineered to meet exacting performance criteria. Each component is part of a 

system, which takes years to design, source, test and validate to meet critical performance standards at an appreciable 

investment by our company.
FTDS Purchasing Americas

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Lack of Production in the United States (con’t)

While it is possible to produce the component elsewhere, this cannot be achieved without a significant and appreciable reinvestment at additional cost associated with tooling, testing and product revalidation. The estimated time to resource and 

revalidate our products is 2 to 4 years timing in a best-case environment. Note that only component level information is 

shared with our supplier. Our agreement language provides for protection of technology; no systems level information is 

shared, and at no time is information shared with the Chinese government

Product are not strategically important for “Made in China 2025”

The base product technology for the subject product is not unique and has existed for many years. Additionally, to our 

knowledge this product is not associated with “Made in China 2025” or any other Chinese industrial initiatives.

Disproportionate Economic Harm to U.S. Interest

There is no U.S. production of these components; as such, no U.S. producers derive a benefit from these tariffs. Our 

customers, and ultimately U.S. automotive consumers suffer hardship in the form of increased prices. Due to competitive 

pressure created by the additional tariff costs, TI Automotive is required to determine if viable supply alternatives exist to 

offset costs associated with product development. Unfortunately, product validation timing of 2 to 4 years does not assist 

us in address these additional costs in the near term. Moreover, the imposition of additional tariff costs on this product 

causes severe economic harm to TI Automotive negatively affecting our competitive standing and profitability. Further, 

there is potential negative effects to our local economies, our communities and the 191 employees at our assembly plant

locations in Michigan and Tennessee.

Proposed Exclusion

TI Automotive respectfully requests that the USTR exclude components classified under HTSUS subheading 

8413.91.9010. Components of this type are essential for the production of our Fuel Delivery Systems in the United 

States, and no comparable components are manufactured in the United States.

Note that the information provided in this exclusion request is complete and correct to the best of our knowledge. We 

request certain quantity and value information contained in the BCI exclusion form be afforded business confidential 

treatment. The disclosure of such information would endanger trade secrets or profitability, and the information would not 

customarily be released to the public. However, this letter does not contain confidential information, and can be released 

as a public document. 

Respectfully submitted,

TI Group Automotive Systems, LLC

Larry Freeman

FTDS Purchasing