Tariff Exclusion Intelligence

← The machinery docket

How importers argue

A survey of what requesters actually wrote in each rationale field, across 1,111 of the 1,111 machinery exclusion requests (100%). Every rule is published so it can be argued with, and every request that matched no rule is counted.

This docket has no outcomes. Nothing below can be related to a grant rate, and nothing below says which argument works. It describes how importers write, in a process that closed in March 2025 without a published decision.

Structured answers — no inference required

These fields are yes/no or short-form on the request form. They are counted exactly as filed.

Subject to an AD/CVD order

Answer as filedRequests
No1,104
Yes7

Will be used for domestic manufacturing

Answer as filedRequests
Yes1,083
No28

Purchased from US or third country in past 5 years

Answer as filedRequests
No342
No.246
Hitachi's heat exchangers are custom designed due to their unique incorporation into compressed air systems. Due to the 124
No, for the reasons articulated above.31
Welly has not purchased any manufacturing equipment from the US or a third country in the last 5 years.31

Filed by a third party (law firm, association, broker)

Answer as filedRequests
No758
Yes353

Free-text rationale fields — machine-coded survey

A request can match more than one code, so percentages do not sum to 100. The unclassified row is the share that matched no rule at all — published because a taxonomy that misses half its corpus should say so.

US availability

n = 1,111 · median answer 329 characters (10th–90th percentile 67–1,125)

CodeWhat the rule looks forRequestsShare
AVAIL.NOT_AVAILABLEStates the equipment is not available or not made domestically38134.3%
AVAIL.LEADTIMECites lead time or delivery delay29826.8%
AVAIL.CAPACITY_OR_SPECCites capacity, capability or specification limits29226.3%
AVAIL.PRICECites price or cost20918.8%
AVAIL.SOME_US_EXISTSConcedes some US source exists14713.2%
AVAIL.NONE_USStates there is no US manufacturer or source1089.7%
AVAIL.NO_COMPARABLEStates no comparable or equivalent equipment exists766.8%
UNCLASSIFIEDMatched none of the rules above 18917%

Third-country availability

n = 1,111 · median answer 326 characters (10th–90th percentile 10–884)

CodeWhat the rule looks forRequestsShare
THIRD.QUALITY_OR_SPECCites quality, specification or capability difference52647.3%
THIRD.EXISTSConcedes a non-China source exists, or names one47142.4%
THIRD.PRICE_OR_LEADTIMEConcedes a source but cites price or lead time30427.4%
THIRD.SEARCHED_NONE_FOUNDSearched third countries and found nothing suitable827.4%
THIRD.NONEStates plainly there is no third-country source454.1%
THIRD.UNAWAREAnswers on knowledge or belief433.9%
THIRD.CHINA_ONLYArgues China is the only or dominant source181.6%
UNCLASSIFIEDMatched none of the rules above 30227.2%

Sourcing attempts

n = 1,111 · median answer 360 characters (10th–90th percentile 112–691)

CodeWhat the rule looks forRequestsShare
SOURCING.EFFORTDescribes an effort, search or approach to an alternative supplier61555.4%
SOURCING.REJECTED_FOR_REASONFound an alternative and rejected it for a stated reason19617.6%
SOURCING.NOT_IDENTIFIEDStates no alternative source could be identified575.1%
SOURCING.QUOTE_OBTAINEDObtained or discusses a quote or bid514.6%
SOURCING.NAMED_ALTERNATIVENames specific alternative suppliers considered333%
SOURCING.BCI_DEFERRED⚠ Defers the answer to the confidential version — the public record carries no substance here40.4%
SOURCING.NONE_STATEDStates no attempt, or answers N/A20.2%
UNCLASSIFIEDMatched none of the rules above 38935%

Supports domestic manufacturing

n = 1,111 · median answer 649 characters (10th–90th percentile 229–1,759)

CodeWhat the rule looks forRequestsShare
DOMESTIC.JOBSCites employment59853.8%
DOMESTIC.INVESTMENTCites investment or capital outlay40536.5%
DOMESTIC.SUPPLY_CHAINCites supply-chain resilience or reshoring29526.6%
DOMESTIC.NEW_CAPACITYCites new or expanded domestic capacity726.5%
DOMESTIC.IMPORT_SUBSTITUTIONCites replacing imports with domestic production151.4%
UNCLASSIFIEDMatched none of the rules above 28926%

Strategic importance / MIC2025

n = 1,111 · median answer 333 characters (10th–90th percentile 11–967)

CodeWhat the rule looks forRequestsShare
STRAT.DENIESDenies strategic importance or MIC2025 relation82073.8%
STRAT.UNAWAREAnswers on knowledge/belief rather than substance827.4%
STRAT.DISTINGUISHESAcknowledges the sector is listed, then distinguishes the specific product292.6%
STRAT.CONCEDESConcedes strategic importance111%
UNCLASSIFIEDMatched none of the rules above 25623%

A rule that was wrong, and how

STRAT.CONCEDES — The first version fired on 56 requests, of which 47 also matched STRAT.DENIES — an 84% false-positive rate. It matched the phrase "is strategically important or related to…" inside sentences that negate it earlier, e.g. "We are not aware that this manufacturing equipment is strategically important or related to ‘Made in China 2025’". It would have reported ~23% of requesters conceding strategic importance.

A second version using JavaScript lookbehind was worse (35.8%), because lookbehind cannot span the preceding clause. The third and current version is compositional: the affirmative phrase must match AND neither a denial nor a knowledge-qualifier may appear anywhere in the answer. That yields 2.5%, consistent with 81.5% denying outright.

Recorded rather than quietly corrected. A keyword rule over legal prose fails first on negation, and a rule whose count is implausible next to its logical opposite is the signal to look for it.

What this survey is not