October ’23 at-a-glance … taxes, tariffs & trade

NAFEM provides input to Section 232 exclusion process review

In comments to the U.S. Department of Commerce (DOC) Bureau of Industry and Security’s (BIS) notice of proposed rulemaking (NOPR), NAFEM requested three actions to improve the exclusion process for the Section 232 steel and aluminum tariffs. Based on valuable input from members, NAFEM requested that BIS:

1. Continue to improve the objection form and require support documentation to increase transparency and fairness of the process.
2. Establish a public request process for industry-specific, general-approved exclusions.
3. Permit trade associations to submit exclusion requests on behalf of members that are not importers of record, or provide an alternative option for small- and medium-sized companies to participate in the process.

BIS incorporated some of NAFEM’s earlier suggestions in its NOPR and the association again urged “BIS’s thoughtful attention to these important matters to help safeguard the nation’s manufacturing supply chain.”

NAFEM provided similar feedback in comments submitted by the Coalition of American Metal Manufacturers and Users (CAMMU). NAFEM also joined comments from the National Foreign Trade Council (NFTC) Tariff Reform Coalition (TRC).

US – EU agreement that replaced Section 232 tariffs with tariff rate quotas (TRQ) on steel and aluminum expires Oct. 31.