Organization Name:

Note: Representatives submitting on behalf of an organization must enter information below.

Requestor Representative:

Section 301 Investigation: China's Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation - Form to Request Exclusion of Product

When submitting a product exclusion request using this form, enter the specified 

information in the following fields and explain the basis and rationale for your statements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge. 

1. Indicate whether the comment contains business confidential information (BCI), is a public

document, or is a public version of a BCI document.

3.

2. Please provide a complete and detailed description of the particular product of concern:

4.

*

10-digit HTSUS item number* for product you wish to address in this product exclusion request:

Use numerical characters only with no special characters (example: 1023456789). For help in finding

the HTSUS item number associated with your product, see https://hts.usitc.gov/

7.

5. Requestor's relationship to the product:

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential information 

(BCI), is a public document, or is a public version of a BCI document.

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1
8. Is this product, or a comparable product, available from sources in the United States? (If you

9. Is this product, or a comparable product, available from sources in third countries? (If you

10. Please provide the value and quantity (with units) of the Chinese-origin product of concern

that you purchased for each calendar year specified. Limit this figure to the products

purchased by your firm (or by members of your trade association) alone. Please provide

estimates if precise figures are unavailable.

2017 Value:

2016 Value:

2015 Value:

2017 Quantity:

2016 Quantity:

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

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

the input accounted for.

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

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:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?

VERSION 2 CONTINUED BELOW 2
12. Please provide information in support your request, taking account of the

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).

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Bosch Rexroth – Addendum to the Exclusion Request

Response to Section 12:

Bosch Rexroth (“the Company or Bosch”) imports gear boxes with a hydraulic motor (e.g. winch drives 

with a separate hydraulic motor attached to it). The gear box with hydraulic motor is manufactured at 

Bosch Rexroth (Beijing) Hydraulic Co., Ltd. located in Beijing, China. Bosch Rexroth in Beijing is 

tasked with manufacturing the gear box with hydraulic motor exclusively for Bosch Rexroth. All such 

gear boxes with hydraulic motors are uniquely designed for the specific size and type of [ ] utilized. It 

would not be possible to purchase any sort of generic assembly to replace these components in fit, form 

and function.

As one of the world’s leading suppliers of drive and control technologies, Bosch Rexroth supports 

mechanical and plant engineering challenges both in the U.S. and around the world. Their systems include 

hydraulics, electric drives and controls, gear technology, and linear motion and assembly technologies, 

including software and interfaces to the Internet of Things (IoTs). Bosch Rexroth provides efficient, 

powerful and safe machinery and engineering solutions to support U.S. manufacturing and factory 

automation. 

Earlier this year Rexroth launched numerous innovations to empower modern manufacturing, from data 

visualization tools to a broad range of connected hydraulics for predictive maintenance and condition 

monitoring in heavy machines and equipment. These Industry 4.0 solutions save time and costs.

Consistent with USTR's Section 301 notice, Bosch 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.

A. Example of Bosch Rexroth’s Winch Drives

B. Made in China 2025

To the best of our knowledge, the Company’s gear box with hydraulic motor does not benefit from 

the Chinese industrial policies and initiatives such as “Made in China 2025.” It is our understanding 

that the Made in China 2025 policy is focused on investment in robotics and other cutting edge 

technologies that take Chinese manufacturing capabilities forward and increase speed and efficiency 

against global competitors. Specifically, this program identifies, for example, priority sectors such as: 

information technology, robotics, aerospace and aviation, maritime engineering, advanced rail 
2

equipment, new energy vehicles, bio-medicine, high-performance medical devices and heavy 

agriculture machinery. This program is not directed at items using low levels of technology. 

The item(s) at issue are not subject to Chinese governmental oversight, control or restriction. The

Bosch Rexroth gear box with hydraulic motor is not strategically important to any Chinese industrial 

programs including Made in China 2025 and contains a low level of technology.

Finally, Bosch Rexroth has not been required to provide any of its intellectual property or technology 

to China as part of the manufacturing of its finished good and none of the production processes utilize 

articles of interest in the Made in China 2025 program. 

The engineering and design associated with the gear box with hydraulic motor is only used by 

Bosch’s legal entity in China. The gear box with hydraulic motor is not subject to any industrial 

policy favoring local production at the expense of foreign made items. 

C. Background on Bosch United States Companies

The Bosch group of companies provide services and products in the areas of automotive and 

industrial technology, consumer goods and building technology. Having established a U.S. presence 

in 1906, the Bosch group of companies today employs more than 18,000 associates at facilities across 

the U.S. For example, Robert Bosch LLC has three dedicated Research and Development Centers 

(Pittsburgh, Pennsylvania; Sunnyvale, California; and Cambridge, Massachusetts) and manufacturing 

and other facilities in Michigan, Illinois, Indiana and South Carolina. Other Bosch companies have 

facilities in Arkansas, California, Florida, Georgia, Kentucky, Minnesota, New York, North Carolina 

and Pennsylvania.

The U.S. has been a competitive location for the Bosch group of companies for many years. Bosch 

continues to actively grow in the U.S. and is planning future investments amounting to approximately 

$152 million to expand the plant in Anderson, South Carolina. This expansion will allow for an 

increase in production of automotive electronic components. Additionally, Bosch is working to 

develop a new Bosch Center for Artificial Intelligence research lab in Pittsburgh, Pennsylvania.

Bosch is also committed to supporting and empowering American workers. Associates at the various 

Bosch companies in the U.S. have access to a broad variety of training programs and skill-building, 

including apprenticeship programs at manufacturing facilities. These opportunities enable current 

employees and students to receive hands-on training and gain valuable experience while working at a 

Bosch site.

In addition, one of Bosch’s top priorities is to support the local communities where various Bosch 

companies operate through grants and volunteering efforts. Since its first grant in 2012, the Bosch 

Community Fund (“BCF”) has awarded more than $20 million to organizations and educational 

institutions across the U.S. In 2017 alone, the BCF provided 183 grants to various organizations in 40 

communities across the country. Bosch associates in the U.S. also volunteer tens of thousands of 

hours to benefit community organizations, including FIRST® Robotics and various other STEM 

educational programs.

D. Financial Hardship 
3

[ ]

E. Customs Enforceability

Bosch requests exclusion for its gear box with hydraulic motor classified under USHTS

8412.29.8045, which provides for, "Other engines and motors, and parts thereof; Hydraulic power 

engines and motors Axial piston type". While imports from China under this subheading may 

continue to be subject to the additional duties under §301, we propose that the abovementioned 

product be excluded through the transmission of the USTR docket exclusion request number (e.g. 

USTR-2018-0025-xxx), or through transmission of any unique exclusion approval number issued by 

the USTR. 

Upon approval of the exclusion, this information will be transmitted to all of our licensed and 

authorized customs brokers and Bosch Rexroth’s internal systems will be updated to reflect the 

approved exclusion. Bosch Rexroth, and its customs brokers, will have the ability to transmit the 

information through ACE via the data field for applicable ruling numbers. Bosch Rexroth will also 

maintain information relevant to any granted exclusion within our internal parts database.

F. Conclusion

As addressed above, these products fall outside of high tech products that are the focus of the Made in 

China 2025 program. Additionally, neither Chinese investors nor the Chinese government sought to 

acquire our processes, procedures, tooling, or factory part resources. [ ]

To the best of our knowledge, the information included herein is complete and accurate.