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Commerce Publishes Forms and Instructions for Section 232 Exclusions

By Robert L. LaFrankie, Yun Gao & Ru Xiao-Graham on March 19, 2018
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On March 19, Commerce published a Federal Register Notice which detailed the procedure to request product exclusions from the new imported steel and aluminum tariffs.

In addition, the agency established two web pages and accompanying exclusion request forms, one each for steel and aluminum, explaining the process, how to file exclusion requests, the detailed information to be provided, and how to file exclusion objections.

Per its new web pages and exclusion request forms, Commerce explains:

  • Exclusion Requests will be open for public review after being posted to the federal rulemaking portal.
  • There is no specific deadline to file exclusion requests, as they may be submitted at any time.
  • During the initial 30 days, U.S. parties may file objections to the exclusion request.
  • After this initial 30 day period, approximately 60 days will be necessary for complete review and vetting of the Exclusion Request and any related Objection Filings.
  • The total processing time for exclusion requests is estimated at 90 business days.
  • A single response to each exclusion request and related objection filings will be posted in regulations.gov indicating if the exclusion request has been granted or denied.

There is a link on each page to the exclusion forms and instructions on how to upload it once completed.

Further, Commerce provided some guidelines, to include:

  • A separate Exclusion Request must be submitted on each distinct type and dimension of aluminum or steel product to be imported.
  • Exclusion Request Requirements: Only individuals or organizations that use aluminum or steel products in business activities in the United States may submit an Exclusion Request. This includes those involved in construction, manufacturing, and supplying steel or aluminum products to users.
  • For an Exclusion Request to be considered, the exclusion requester must provide factual information on:
    • 1) the single type of aluminum or steel product they require using a 10-digit HTSUS code, including its specific dimension;
    • 2) the quantity of product required (stated in kilograms) under a one-year exclusion; and
    • 3) a full description of the properties of the aluminum or steel product it seeks to import, including chemical composition, dimensions, strength, toughness, ductility, magnetic permeability, surface finish, coatings, and other relevant data.
  • All exclusion requests will be reviewed for completeness. Only fully completed exclusion requests will be considered and posted for public review. All exclusion requests will be made available for public inspection and copying.
Photo of Robert L. LaFrankie Robert L. LaFrankie

Robert L. LaFrankie is a partner in Crowell & Moring’s International Trade Group and resident in the firm’s Washington, D.C. office. Bob regularly advises manufacturers, exporters, and importers in all aspects of international trade and customs proceedings before various government agencies, courts, and…

Robert L. LaFrankie is a partner in Crowell & Moring’s International Trade Group and resident in the firm’s Washington, D.C. office. Bob regularly advises manufacturers, exporters, and importers in all aspects of international trade and customs proceedings before various government agencies, courts, and international tribunals. He focuses on trade-related litigation and counseling, including trade remedy proceedings and U.S. Customs compliance and enforcement issues. Bob has successfully defended numerous clients located throughout Asia, Europe, and the Americas that produce or import a diverse range of products, including flat-rolled and specialty steel products and components, chemicals and plastics, frozen and canned food products, paper products, motor vehicle parts and components, specialty valves and valve systems, disposable lighters, petrochemical and renewable fuels, anti-friction bearings, and other manufactured products. In addition to litigation and compliance counseling, Bob engages in strategic trade remedy and customs planning activities for clients, particularly for companies with global sourcing, manufacturing, and export/import operations. He also advises companies with regard to NAFTA compliance issues and related audits of client facilities.

Read more about Robert L. LaFrankieEmail
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Photo of Ru Xiao-Graham Ru Xiao-Graham
Read more about Ru Xiao-GrahamEmail
  • Posted in:
    Business and Commercial
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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