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 product of concern:

4.

5. Requestor's relationship to the product:

CONTINUED BELOW

*

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/

1

7.

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.

VERSION 1

Requestor Information

Requestor Name (Last, First):
END 2

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

VERSION 1

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).

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.

2016 Value:

2015 Value:

2017 Value:

2016 Quantity:

2015 Quantity:

2017 Quantity:
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

October 8, 2018 

VIA REGULATIONS.GOV PUBLIC DOCUMENT 

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 Metcal Soldering Cartridges under HTSUS 8515.90.4000 from the 

Determination of Action Pursuant to Section 301 

Dear Ambassador Lighthizer: 

OK International Inc. (“OKI”), a subsidiary of Dover Corporation (“Dover”) respectfully submits 

this request for exclusion of Metcal Soldering Cartridges from the proposed determination of action 

pursuant to Section 301 of the Trade Act of 1974.1

 

Dover is a U.S. manufacturer and importer of diversified products, including innovative equipment 

and components, specialty systems, and consumable supplies, headquartered in Downers Grove, Illinois. 

Dover works closely with manufacturing customers to create engineered systems that drive efficiencies in 

the industrial equipment market through its subsidiary OKI, which is based in Cypress, California. OKI 

produces bench tools and equipment that are used in electronics and industrial product manufacturing and 

assembly. 

OKI traces its roots back to 1946, when it specialized in precision machining of metal parts 

primarily for the defense industry. In 1989, OKI made a strategic decision to refocus on developing, 

 

1

 19 U.S.C. § 2411. 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

manufacturing, and marketing its own proprietary products, primarily in the circuit board solder and 

desolder business. In alignment with that strategy, OKI acquired Metcal and Techcon Systems in 1996. 

These acquisitions, along with becoming part of Dover in November 2000, served to strengthen OKI’s core 

competencies in the manufacturing and development of soldering systems. This also helped OKI to expand 

its customer base, markets, and geographic presence. In addition, these acquisitions provided OKI with 

patented technologies and products that broadened its product line. 

Today, OKI generates $41 million in U.S. sales per year and $52 million in global sales. OKI’s 

operations in Cypress, California employ 140 engineers, administrative, sales, customer service, quality, 

product management, production, warehouse, and purchasing personnel. About half of these employees are 

salaried, professional positions that support middle-class families in the United States. Nearly 20 percent of 

OKI’s workforce are Salaried Engineers, Manufacturing Engineers, Quality Engineers, and Technical 

Service Engineers. More than one-third are manufacturing positions on OKI’s U.S. production lines. In 

total, OKI invests $12.8 million in employee payroll and benefits each year. 

The soldering systems, cartridges and fume extraction equipment included on the USTR’s Section 

301 product list are part of OKI’s Metcal product line.2

 Metcal is OKI’s benchtop solutions division that 

delivers broad value to customers since its Silicon Valley beginnings in 1982. Offering unrivalled 

performance, risk mitigation, and ROI, it gives electronics manufacturers in the automotive, aerospace, 

communications, medical devices and military sectors the tools and the confidence they need to develop 

faster, safer, more advanced products. Metcal provides advanced technology products across hand soldering 

 

2

 Soldering systems, cartridges and fume extraction equipment are complementary products imported under 

HTS 8515.11.00, 8515.90.40 and 8421.39.80. 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

applications, as shown in Figure 1 below. The soldering equipment produced by Metcal transfers heat to 

create a solder joints for rework and assembly of circuit boards. 

Figure 1: 

Hand Soldering Tools 

 

As discussed in more detail below, OKI imports soldering systems and cartridges from China to 

support American businesses in nearly every segment of the U.S. market, including the technology, medical, 

automotive, aerospace, and engineering sectors. OKI’s customers include fortune 500 companies, military 

contractors, and technology start-ups, as well as small-, medium-, and minority owned-businesses in the 

United States. 

This exclusion request addresses Metcal Soldering Cartridges classified under HTSUS subheading 

8515.90.4000, which are currently subject to the 25% additional Section 301 tariff. Please note that a 

separate Section 301 Investigation Form to Request Exclusion of Product has been submitted for each 

unique part number for which we are requesting an exclusion. 

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

(“USTR”),3 OKI provides the following information requested by the USTR in support of this request. 

 

3 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). 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

1. Availability of the product outside of China, i.e. whether the particular product and/or a 

comparable product is available from sources in the United States and/or in third countries 

OKI sources soldering systems and cartridges from affiliated and third party suppliers in China to 

best meet the specifications required by its customers in the technology, medical, automotive, aerospace, 

and engineering industries. For example, OKI produces soldering cartridges in China using automated 

equipment to protect its manufacturing operations and employees in the United States. Specifically, these 

high-volume products are best suited for automated production, which is localized at OKI’s wholly-owned 

facility, Dover Shenzhen, in China. Lower volume production lines, such as OKI’s MFR cartridges, are 

produced by U.S. workers at OKI’s facility in California. OKI’s U.S. operations employ twice as many 

workers as its operations in China. 

There is no viable option for sourcing these products from an outside domestic supplier in the United 

States. For soldering systems and cartridges, including for all of OKI’s competitors, the vast majority of 

product is produced outside of the U.S. and imported from a foreign supplier. It is also not feasible for OKI 

to shift to a third country supplier due to the robust qualification requirements and supply chain restrictions 

in the industries that use these products. Specifically, OKI’s suppliers undergo extensive qualification, 

including TUV, UL, and customer base certifications. The specifications for each of OKI’s products varies 

by industry and each critical component along with their suppliers and the finished product must all be 

qualified individually. The entire qualification process takes at least 12 months. In addition, customers in 

the military, medical, and aerospace fields must also qualify the finished product, which will take an 

additional three months or more. This is costly and disruptive to the customers. The inconvenience of the 

qualification process may drive the customers to shift their business to competitive products, largely from 

foreign suppliers, that have already been qualified. 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

OKI’s Chinese suppliers have been fully certified and approved by customers in all industries we 

supply. A change in suppliers would require significant time, money, and resources to find new suppliers, 

conduct retesting, redesign production processes, and requalify the new facilities. Such substantial changes 

to OKI’s supply chain would cause disproportionate harm to OKI’s business, including engineering and 

manufacturing processes, and jeopardize OKI’s ability to meet customers’ production demands. 

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

economic harm to the requester or other US interests 

Soldering systems and cartridges should be excluded from the list of products subject to a 25 percent 

tariff pursuant to Section 301. The imposition of an additional duty on these products will be ineffective in 

eliminating China’s discriminatory acts, policies, and practices, while at the same time causing 

disproportionate harm to OKI’s business and employees, and the diverse U.S. businesses that depend on 

OKI for their supply. 

The imposition of 25 percent tariff will cause severe economic harm to U.S. interests, including 

small- and medium-size businesses and consumers that depend on the consumer goods supported by the 

soldering systems and cartridges at issue here. 

The 25 percent tariff on these products will impact OKI’s profitability and, ultimately, have a 

negative effect on its sales and reduce its profits by over $1.2M annually. The increased costs will impact 

OKI’s ability to maintain current operations and employment levels in the United States. OKI’s operations 

also support downstream U.S. manufacturing operations, which will likewise be adversely effected by the 

high tariff. For example, one of the critical components in soldering cartridges is a hand soldering heater, 

which is manufactured by U.S. heater fabrication suppliers in Massachusetts, New York, Tennessee, and 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

California, and exported by OKI to China. The tariff will cause the sales and profits of these American 

businesses to decline, threatening their workers and continued operation in the United States. 

Moreover, OKI cannot fully absorb the large cost increases resulting from the tariff and will be 

forced to raise prices to its customers. OKI’s customers currently purchase soldering systems and cartridges 

from OKI, a U.S. based company, rather than its foreign competitors. OKI produces high-quality and highend performance equipment and has a technology advantage over its competitors, which commands a 

slightly higher price in the U.S. market. The imposition of a tariff on these products will make OKI’s prices 

less competitive and give foreign competitors, which are located outside the U.S., a cost advantage over 

U.S. suppliers. With the additional costs, OKI’s customers are no longer able to justify paying higher prices 

for OKI’s higher quality product, and will be forced to rely on lower quality alternatives from foreign 

sources. 

As previously discussed, OKI’s customers in the technology, medical, automotive, aerospace, and 

engineering industries will either turn to the lower-quality soldering systems and cartridges offered by 

OKI’s foreign competitors in the U.S. market or be forced to pay higher prices for OKI’s premium products. 

Either option is disproportionally harmful to U.S. consumers and U.S. interests. Soldering systems and 

cartridges, for example, are used on practically every product with a battery or electrical socket, from cell 

phones, to satellites, vehicle electronics, and even clocks. Virtually all Americans, therefore, benefit from 

and depend upon these products every day. 

All of OKI’s technology, research, and development are generated and held in the United States. 

OKI spends $2.5M, or 6.1 percent of its U.S. sales, on R&D and Engineering in the U.S. annually and 

designs and owns the intellectual property for all of its products. 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

For these reasons, the 25 percent increase in the rate of duty on these products is detrimental to 

American consumers and to U.S. interests. 

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

or other Chinese industrial programs 

Imposition of the 25 percent tariff is intended to eliminate China’s discriminatory licensing 

requirements, foreign ownership restrictions, state-funded acquisitions, and state-backed hacking operations. 

The soldering systems and cartridges that OKI is requesting to be removed from the USTR’s list have not 

benefitted from the Chinese acts, policies and practices targeted by this tariff. 

While there have been increases in the importation of certain HTS headings in 2017 and interim 

2018 (i.e., HTS 8515.90.40) these increases were consistent with the total value of imports from all 

countries. Indeed, China’s share of total imports has remained steady since 2015, indicating that Chinese 

imports of soldering systems and cartridges have been a consistent presence in the U.S. market for years. 

Clearly, there has been no surge of Chinese imports of these products resulting from any unfair or 

preferential policies related to technology transfer, intellectual property, or innovation. 

The soldering systems and cartridges at issue are manufactured at OKI’s wholly-owned facility in 

China. There is no evidence that China has misappropriated intellectual property as to these products, which 

are produced based on OKI’s specifications to support its customers in the U.S. market. 

OKI’s intellectual property is protected by patents, on which the company spends more than 

$300,000 each year. There has been no coercion or other acts, policies, and practices on the part of the 

Government of China to attempt to improperly transfer OKI’s intellectual property to the Chinese 

government or to other Chinese companies. In short, OKI has not encountered the acts, policies and 

practices described in the USTR’s Section 301 report. 
10800 Valley View Street, Cypress, CA 90630 • Tel: 714 799-9910 • Fax: 714 828-2001 • www.okinternational.com 

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

undersigned if you have any questions regarding this submission. 

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

Respectfully submitted, 

 

 ___________________ 

 Doug Noyes 

 Director of Global Operations 

 OK International, Inc. 

 (714) 799-9910