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ACSAT Urges Commerce to Revise Regulations Governing the 232 Tariffs Exclusion Process

Washington D.C. – The National Foreign Trade Council (NFTC) today submitted comments to the Department of Commerce on behalf of the Alliance for Competitive Steel and Aluminum Trade (ACSAT). The comments highlight numerous issues with the process to apply for exclusions from the Section 232 tariffs on steel and aluminum. 
ACSAT represents a broad cross-section of industries that produce intermediate and finished goods containing steel and aluminum, as well as a wide range of manufacturers and farmers who are suffering from the direct and indirect consequences of these unilateral tariffs on steel and aluminum. In submitting these comments, the Alliance is supported by 48 trade associations covering a wide variety of industry sectors.
“We strongly believe that tariffs are not the right way to address global overcapacity in steel and aluminum created by China’s unfair trade practices. We believe instead that the U.S. should work within the existing global framework of trade rules to address these practices,” said Rufus Yerxa, President of the NFTC. “Businesses all across the country have been gravely affected by these tariffs, and the cumbersome and inefficient exclusion process is only making matters worse. The process is confusing and costly, and it is disproportionately affecting small and medium-sized manufacturers all over the country who do not have the expertise or resources to effectively participate in the process.”
In the comments, ACSAT addresses a number of deficiencies in the regulations that Commerce is using to govern the exclusion request process. Specifically, ACSAT criticizes Commerce for not allowing trade associations to file an exclusion request on behalf of their members and to not approve exclusions that can apply to all users of a product. Through the comments, ACSAT also question Commerce’s need for separate request filings for products which have only minor variations, such as width or length differences. Finally, they question why Commerce has not developed a way for companies to protect from public disclosure business confidential information which may be relevant to a product exclusion request. Such information is routinely protected from public disclosure in other Commerce Department administrative trade proceedings. 
The deficiencies in the product exclusion request process are negatively impacting U.S. manufacturers and their ability to obtain product exclusions in a timely and efficient manner. The Alliance urges Commerce to revise the regulations governing this process to ensure that U.S. companies can obtain the relief they deserve in this challenging trade environment.
To read the full comments, click here

About the NFTC

Serving America's Global Businesses Since 1914- The National Foreign Trade Council ( is a leading business organization advocating an open, rules- based global trading system. Founded in 1914 by a broad-based group of American companies, the NFTC now serves hundreds of member companies through its offices in Washington and New York.
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