Dear USTR Representative:

On behalf of Hartland Controls, LLC, we respectfully request the amendment of the Annex language in 

Federal Register Vol. 84, No. 183, September 20, 2019 (49583), Annex 2 (217) to amend the description 

to “not over $4.00,” rather than “not over $1.50” as this unit value is the result of averaging BCI annual 

import values rather than actual unit prices. Individual unit prices were not requested in the original 

USTR exclusion request instructions.

Docket ID: USTR-2018-0025-6851

Organization Name: Hartland Controls, LLC

Summary of Issue: Current value limitation as listed in the approval published on September 20, 2019 

(Fed. Reg Vol 84 No 183 at 49583 to Annex 2 (217) is too restrictive: Current Language (the language 

that is too restrictive is listed in blue): Aluminum electrolytic capacitors each valued not over $1.50

(described in statistical reporting number 8532.22.0055) 

Requested Amendment (requested change in yellow): Aluminum electrolytic capacitors each valued not 

over $4.00 (described in statistical reporting number 8532.22.0055)

Explanation and Support for the Requested Amendment: The universe of capacitors falling within the 

exclusion is currently listed in Annex 2 (217 ) as applying to individual capacitors valued not over 

$1.50. The Hartland Control LLC capacitors for which it received the USTR exclusion approval range in 

value up to $4.00 per unit. The original BCI submission listed the total annual import values for 2017-

2019. The $1.50 unit value in the published Annex represents the average unit price based on the 

total annual import values and quantities. The original USTR BCI instructions requested annual values 

and quantities. Individual unit prices were not requested. As the HTSUS 8532.22.0055 classification 

differentiates capacitors by diameter dimensions and not unit price, Hartland Controls LLC did not 

provide this information in its product description. The capacitors at issue are described immediately 

below for ease of reference.

For background purposes, the capacitors at issue are described in docket # USTR-2018-0025-6851 as 

follows:

The Product of Concern, a Hartland Controls Motor Run Capacitor (the “Product”), is an aluminum 

electrolytic, fixed electrical capacitor, with diameters between 35 and 50mm, which is classified as 

HTSUS 8532.22.0055. The Product directs current to one or more windings of an AC induction motor 

which increases the current or reduces the power factor to an electric motor. The Product is housed in 

an aluminum canister, which contains the sealed internal components of an aluminum film electrolytic 

capacitor. The internal sealed components consist of an etched aluminum foil anode electrode, tin 

plated brass terminals and vegetable oil. The Product contains the UL, CE and CSA rating label, HCC part 

number, operating temperature and country of origin.

The Run Capacitors are available in both round and oval canister models and have rated voltages 

between 370 and 440VAC. They range in size from 25-50mm in diameter, 34.5-51mm (length), 56-

143mm (height) and have a weight range from .15 lb to .5 lb. The attached specification sheet provides 

photographs of the Product along with additional specifications. The Product is identified on the 

commercial invoice as “Run Cap Oval,” “Run Cap Rnds,” “Oval Run Capacitor,” “Round Run Capacitor,” 

“TP-Cap,” and “Cap.”, with part numbers HCKS XXXXXX, HCKY XXXXXXX, and HCK XXXXXXX, where the 

X’s represent the capacitance and voltage.

We are very appreciative for your assistance on this matter. Please do not hesitate to contact us if you 

require additional information.

Kind regards,
Megan Finkelstein