Comments on Section 232 Exclusion Process

In September, the Department of Commerce amended the rules for requesting steel and aluminum exclusions from the Section 232 tariffs.  The “Revisions to Requirements for Submissions of Exclusion Requests and Objections to Submitted Requests for Steel and Aluminum” included changes such as allowing rebuttals to objections by the entities that requested the exclusions, “surrebuttals” to the rebuttals, and a pledge to “expeditiously” grant exclusions if there were no objections.  Commerce requested comments from the public about these changes.  The Coalition of American Metal Manufacturers and Users submitted comments on these revisions.

The Coalition stressed that the best solution to the problems faced by steel- and aluminum-using manufacturers would be to eliminate the tariffs; however as long as the tariffs remain, it is essential for the exclusion requests be fair, transparent and processed in an expeditious manner.  The Coalition made comments in four specific areas:

  • “Not Available Immediately” Definition a Positive Step
  • 106 Day Target Timeline Too Long – Should Deem Approved if Complete with No Objections
  • Improving Transparency: More Action Needed on Tracking Sheet, Clarity When Denied
  • Department Should Use its “Discretion to make exclusions available to all importers”

Read the full comments here.