Public Document

This exclusion request is for high pressure casting die and die components made of H13 tool steel, 

product number M202 Universal Holding Block #H. This product is TAH Holding Block Stationary. It's 

dimensions are: 1700x1800x650. It is used in high pressure casting die to produce transmission parts for 

automotive OEM customers. The commercial name for these is Die Components. They are shipped on 

crates with “M202 Universal Holding Block #H” clearly indicated on each accompanying packing slip 

to facilitate the administration of the 301 tariffs by CBP.

8480490000

Koursova, Larissa

Aisin World Corp. of America

David Hamill, PARTNER, Arent Fox LLP

Purchaser

YES

Public Document

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. 

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

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

I I 

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

3. I 0-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/ 

4. Requestor Information 

Requestor Name (Last, First): 

Organization Name: 

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

Requestor Representative: 

5. Requestor's relationship to the product: 

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

7. Please indicate whether any additional attachment contains business confidential 

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

VERSION 1 CONTINUED BELOW 1 
NO

NO

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* This is a new product that has not historically been imported, but will be imported in the 

upcoming months due to previously planned production

See attached for arguments in support of this exclusion request.

8. Is this product, or a comparable product, available from sources in the United States?: 

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

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. 

2017Value: 

2016 Value: 

2015 Value: 

2017 Quantity: 

2016 Quantity: 

2015 Quantity: 

11. Please provide information in support your request, taking account of the instructions 

provided in Section B of the Federal Register notice (note: text entered below can extend 

beyond the apparent size of this box). 

VERSION 1 END 2 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551 Fax: (734) 453-4670

1 

October 9, 2018 

VIA REGULATIONS.GOV PUBLIC 

The Honorable Robert E. Lighthizer Docket No. USTR-2018-0025 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street, NW, Room F516 

Washington, D.C., 20006 

Re: Request for Exclusion of High Pressure Casting Die Components from the Determination of Action 

Pursuant to Section 301 Tariffs

Dear Ambassador Lighthizer: 

Aisin AAC respectfully submits this request for exclusion of high pressure casting die components from 

the proposed determination of action pursuant to Section 301 of the Trade Act of 1974.1

Aisin Group is the sixth largest, global Tier One supplier of automotive components and systems such as 

brakes, transmissions, navigation systems, drivetrain, chassis, body, engine-related parts, electronics and 

intelligent transportation systems. The company is the largest transmission manufacturer in the world. Aisin 

Holdings of America, located in Seymour IN, is responsible for North American operations, serving as an 

information center, structuring business strategy, and administrating the subsidiaries in North America. Aisin 

World Corp. of America headquarters are in Northville Michigan. In addition, our research and development 

capabilities can be found throughout the United States. 

AISIN AAC is located in London KY where our employees are committed in producing high quality, 

functional, engine components for some of the largest automotive manufacturers in the United States. 

1

 19 U.S.C. § 2411. 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551 Fax: (734) 453-4670

2 

Our approach has always been to follow a global strategy and establish our family of companies in the 

U.S.to support the U.S. domestic and U.S. import manufacturer base. 

Our U.S. operations are a key division in our global company. Yet as this Administration has understood, 

our companies are facing enormous competitive challenges in the global automotive industry. Government 

regulatory action by our trading partners are one example, but one of many. Looking mid- to long range, our 

strategy in the United States is to squarely focus on the car of tomorrow. This means investments in new 

technologies and a highly trained and skilled workforce. To this end, we partner with our downstream suppliers 

as well as the OEM customers. For AISIN AAC, this is an investment for the future we gladly make. 

AAC purchases these high pressure die casting components because they meet our strict engineering 

requirements. We are unaware of any other source, in the United States or abroad, which can supply the same 

product to our specific needs and those of our OEM customers in the United States. 

We are constantly striving toward product improvement that will benefit consumers and its emphasis on 

environmental sustainability, community involvement and employee life balance, Aisin consistently lives up to 

its motto: “For a Better Tomorrow.” 

This exclusion request addresses die and die components classified under HTSUS subheading 

8480.49.0000 which are currently subject to the 25% additional Section 301 tariff. 

In accordance with the procedures released by the Office of the United States Trade Representative 

(“USTR”),2 AAC provides the following information requested by the USTR in support of this request. 

2 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. 32,181 (USTR July 11, 2018). 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551 Fax: (734) 453-4670

3 

1. Availability of the product outside of China 

The high pressure die casting components are a key component of our operations in the United States. The 

product as required by our company is only available from China. Our U.S. customer specifications are exact 

and rigorous. AISIN AAC is not aware of any immediately available U.S. or third-country sources for the same 

or comparable products. Furthermore, any supplier-change would require at least one year of testing and 

customers’ requalification and approval. Nor are we aware of any emerging capacity in the United States which 

could immediately provide AISIN AAC and our US customers with a validated product. For an automobile, the 

quality and consistency of materials and components are of the utmost importance because they can impact the 

vehicles quality, safety, and performance. 

In short, these products from China had met the final approval of our automotive partners and customers in 

the United States. The process to validate a new supplier will require extensive testing to validate the product, 

both for our purposes as well as our OEM customers. This testing, depending on the customer requirements and 

usually could take 12 to 18 months to complete. More importantly perhaps, as we noted above, there is 

significant risk involved with the quality and delivery aspects of this revalidation in terms of production 

schedules 

These products, as specifically configured to our production needs, is not available outside of China. The 

company’s U.S. operations would suffer economically if we were forced to locate an alternative supplier as this 

would engender significant delay costs, requalification assessment costs, and potential loss of our OEM 

customer. In fact, any supplier change would require one year (or possibly more) to meet our customer approval 

demands. 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551 Fax: (734) 453-4670

4 

2. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requester or other US interests 

The high pressure die casting components purchased by AISIN AAC that are included on the USTR’s 

product list are key components of our automotive parts manufacturing and are imported to support domestic 

manufacturing operations and American jobs in the United States. The imposition of a 25% tariff on these 

automotive parts could cause severe economic harm to U.S. interests, including our employees, our customers, 

and consumers, who eventually will be paying higher prices for new vehicles. Specifically, any future business 

opportunities involving these products could be directly impacted by the price increase caused by the additional 

tariff. Our concern here is that the 25% tariff will impact the company’s production costs, reducing profit 

margins and therefore minimizing any future R&D investments, in the long-run negatively impacting 

production strategy. This will, in turn, adversely affect a broader spectrum of U.S. interests, including U.S. 

investments, and jobs. 

3. Whether the particular product is strategically important or related to “Made in China 2025” or other 

Chinese industrial programs 

The imposition of a 25% ad valorem duty on these components from China will not impact the Chinese 

intellectual property violations these seek to eliminate. Section 301 tariffs are aimed at specifically targeted 

products that have benefitted from the China’s acts, policies, and practices detailed in the USTR’s Section 301 

Report. Made in China 2025 aims to promote their indigenous research and development capabilities. The these 

high pressure die casting components are not a new technology. 

We appreciate the Department’s consideration of this exclusion request. Please contact the undersigned if 

you have any questions regarding this submission. 

AISIN • 

A/SIN GROUP 
15300 Centennial Drive, Northville, MI 48168

Tel: (734) 453-5551 Fax: (734) 453-4670

5 

I hereby certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted, 

Larissa V. Koursova 

Assistant General Manager, Purchasing 

Aisin World Corp. of America 

Phone +1 734 582 7654 

Mobile +1 248 756 9958 

lkoursova@aisinworld.com 

AISIN • 

A/SIN GROUP