U.S. industry officials are arguing that any import restrictions that may be ordered in the Department of Commerce’s ongoing national security investigation of steel should cover not only traditional steel products but also downstream goods that incorporate steel. Industries and companies that import such goods have until May 31 to submit comments, data, analyses, and other information to oppose this potential outcome.

DOC has self-initiated an investigation under section 232 of the Trade Expansion Act of 1962 to determine whether imports of foreign-made steel are threatening or impairing U.S. national security. DOC is expediting this investigation and could send its recommendations to the president by the end of June. Tariffs, quotas, restraint agreements, or other import adjustment measures the president may then elect to take would be imposed within 15 days of a decision to do so.

At a May 24 hearing Commerce Secretary Wilbur Ross indicated that DOC is considering a number of issues as part of this investigation, including the form of any potential relief measures and whether they should cover all steel products from all source countries or exclude specific products or countries.

Also at this hearing some domestic industry representatives urged relief for not only steel but also goods containing steel. Transformers, forgings, pipe flanges, and articles made from high-quality cold-finished steel bar were among the goods mentioned at the hearing, and others are expected to be raised in public comments. This would represent a significant expansion of any potential relief and could complicate supply chains and drive up prices for a wide range of manufacturers and businesses.

Those who may be affected by import restrictions on steel or steel-containing products have until May 31 to submit comments to DOC. For assistance in preparing and submitting comments, or if you have other questions concerning this investigation, please contact Kristen Smith at (202) 730-4965, Mark Ludwikowski at (202) 730-4967, or David Craven at (312) 279-2844.

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Kristen S. Smith
Member, Trade Remedies Practice Group Leader

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