Objections from the Section 232 National Security Adjustments of Imports of Steel and Aluminum

OMB Control Number: 0694-0138

Expiration Date: 3/31/2019

Objection Filing to Posted Section 232 Exclusion Request: Aluminum
Objection Filing Requirements: Any individual or organization in the United States may file an Objection to an Exclusion Request. Where relevant, organizations must provide factual information on 1) the aluminum products that they manufacture in the United
States, 2) the production capabilities at aluminum manufacturing facilities that they operate in the United States; and 3) the availability and delivery time of the products that they manufacture relative to the specific aluminum product that is subject to an Exclusion
Request. For an Objection Filing to be considered, it must be submitted as an electronic document using this Excel-based template. Paper submissions will not be accepted.
Organizations submitting an Objection Filing on an Exclusion Request should provide specific information, as relevant, on the product that their company can provide that is comparable to the aluminum product that is the subject of the Exclusion Request. This
information should include 1) discussion on the suitability of its product for the application identified by the Exclusion Requestor, and 2) a full technical description of the properties of the product it manufactures relative to specifications provided in the Exclusion
Request posted on regulations.gov, including information on dimensions, strength, toughness, ductility, surface finish, coatings, and other relevant data.
A separate Objection Filing must be submitted on each Exclusion Request, citing the specific aluminum product and dimension covered in the request posted on regulations.gov. All applicable question blocks in this form must be completed for the Objection Filing to
be accepted for consideration. Organizations electing to attach supporting documents must provide a single submission only in PDF format that must not exceed 25 pages in total. All information submitted in the Exclusion Request is subject to public disclosure. Do
not provide sensitive Personally Identifiable Information.
Organizations should upload their Objection Filing covering a single aluminum Exclusion Request to the corresponding Exclusion Request on https://www.regulations.gov/ under Docket Number BIS-2018-0002. An Objection Filing must be submitted to regulations.gov
no later than 30 days from the date the Exclusion Request is posted in regulations.gov. Processing of the Exclusion Request, including consideration of Objection Filings, will take approximately 90 business days. When Exclusion Requests are approved, notification will
made on regulations.gov. For questions related directly to completing this form, contact BIS via email ([email protected]) or telephone (202-482-4757).
Instruction: State the name, address, and related contact information for the organization submitting the Objection Filing. Provide the same information for the Exclusion Requestor that is the subject of this Objection Filing, relying on information in the request
notice posted on regulations.gov. Also provide the regulations.gov identification number issued for the submitter of the Exclusion Request, the HTSUS code for the aluminum product, and annual quantity of imported aluminum product at issue. This information is
found in the Exclusion Request document posted on regulations.gov
Organization Filing Objection to Requested Exclusion

1.a

Organization Requesting Exclusion

Full Organization Legal Name

Full Organization Legal Name

Street Address

Street Address

City

City

State

State

Zip Code

Zip Code

Headquarters Country
Point of Contact Name
Phone Number
E-mail Address
Web Site Address
regulations.gov Identification #

Annual Exclusion Quantity
Requested (Kilograms)

10-Digit HTSUS Code

Identify the reasons your organization objects to an Exclusion Request being granted to the applicant cited above. Written comments may be submitted (not required) to supplement information that your organization has provided in the Objection Filing form on the
Exclusion Request, but total attachments may not exceed 25 pages. Organizations making an Objections Filing should identify factual problems that they encounter in the Exclusion Request (e.g., product description).
Indicate what type of order the Exclusion Request that is the subject of the Objection Filing would pertain to:
1.b
Comments
Is the aluminum product type identified in the Exclusion Request currently manufactured by your organization in the United
1.c States , or can it immediately be made (within 8 weeks) by your organization, in a company-owned plant in the United States?
If “Yes” identify the location(s) of your aluminum production facilities in the United States.

1.d

This organization does not currently manufacture the identified aluminum product, but can produce the product identified in
the Exclusion Request within the following time period at the following facilities:

-Yes/No-

City

State

Current Annual Plant
Production Capacity (mt)

% Plant Utilization
Current

Days

City

State

Current Annual Plant
Production Capacity (mt)

% Plant Utilization
Current

-Yes/No-

City

State

Current Annual Plant
Production Capacity (mt)

% Plant Utilization
Current

Days

City

State

Current Annual Plant
Production Capacity (mt)

% Plant Utilization
Current

Comments
Does this organization currently manufacture, or can immediately manufacture (within 8 weeks), in a company-owned plant
located in the United States a substitute product for the identified aluminum product that has similar form, fit, function, and
1.e
performance? If “Yes” identify the location(s) of your aluminum production facilities in the United States, current plant
capacity and utilization

1.f

This organization does not currently manufacture the identified aluminum product, but can make a substitute product that has
similar form, fit, function, and performance within the following time period at the following facilities:

Comments
Continued On Next Page
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Objection Filing to Posted Section 232 Exclusion Request: Aluminum - Continued
2.a Select "Yes" for any assertions identified in the Exclusion Request that your organization is challenging:

No Production Capacity

Product Quality

Shipping Time

Insufficient Volume

Unique aluminum Product

Other (specify here)

Discuss 1) the suitability of your organization's aluminum product compared to that identified by the Exclusion Requestor, and 2) provide a full technical description of the properties of the product it manufactures relative to specifications cited in the Exclusion Request
posted in regulations.gov. This description must include information on dimensions, plus performance factors such as strength, toughness, ductility, magnetic permeability, surface finish, coatings, and other relevant data.
2.b

State the chemical composition of the specific aluminum product that your organization can manufacture at a company-owned production facility located in the United States. Numbers may appear rounded, but full values will be stored.
Chemical Composition
Chemical

Aluminum

Antimony

Bismuth

Boron

Carbon

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Molybdenum

Nickel

Niobium

Phosphorous

Selenium

Silicon

Sulfur

Tin

Titanium

Tungsten

Vanadium

Zinc

[Other - List
Below]

[Other - List
Below]

Minimum %
Maximum %
2.c
Chemical
Minimum %
Maximum %

Comments:

Provide the following information on the single aluminum product that is the subject of this Objection Filing: 1) dimensional information covering the single aluminum product subject to the Exclusion Request; 2) performance data for tensile strength, yield strength,
hardness, impact, shear and test temperature. Numbers may appear rounded, but full values will be stored.
Aluminum Product Specifications (Millimeters)

Thickness

2.d

Inside Diameter

Outside
Diameter

Length

Toughness
(If Applicable)

Strength

Width

Height

Tensile
Strength
Mega Pascal
(MPa)

Yield
Strength
Mega Pascal
(MPa)

Hardness
(specify method
below - Brinnell,
Rockwell,
Vickers, etc.)

Test Type

Drop-Weight
Tear Testing

Other
Impact (Charpy)
(specify type in
Testing
comment box)

Temperature
(°C)
Minimum

Joules

Maximum

% Shear

Comments:
Provide the following information on the single aluminum product that is the subject of this Objection Filing: 1) performance data for ductility, magnetic permeability, surface finish; and 2) metal coating process, material type,
weight, and thickness. Numbers may appear rounded, but full values will be stored.
Global Ductility

Elongation %

2.e

Reduction
-in-Area %

Local Ductility
(If Applicable)

Hole Expansion
%

Surface Finish
(If Applicable)

Bendability
(Bend
Radius/Sheet
Thickness
[millimeter]

Profilometer
- [SAE J911]

Coating Type and Composition
(If Applicable)
Composition
Coating Product (e.g., Zn, Al, Si,
Weight
Name and
Mg, other
[Grams per Sq.
Coating Method
Abbreviation
intentionally
Meter]
added elements
or alloys

Minimum
Maximum
Select any additional processing methods used:

Other (specify)

Comments:
Continued On Next Page
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Coating
Thickness
[micrometers]

Objection Filing to Posted Section 232 Exclusion Request: Aluminum - Continued
3.a What percentage of the total aluminum product tonnage requirement covered under the Exclusion Request that is the subject of this Objection Filing can your organization manufacture at its U.S. plants on a timely basis?
3.b State the number of days required by your organization to ship from its U.S. manufacturing plant the aluminum product covered by this Exclusion Request from the time the purchase order is received:
3.c State the number of days required to manufacture the aluminum product covered by this Exclusion Request from the time a binding purchase order is received:
3.d State the delivery time in days for the aluminum product covered under this Exclusion Request from the time it is shipped from your manufacturing plant to the Exclusion Requestor's loading dock:

Comments:

Identify the reasons your organization objects to an Exclusion Request being granted to the applicant. Written comments may be submitted (not required) for each of the reasons your organization has cited in the Objection Filing form. Organizations filing Objections
should identify factual problems in the Exclusion Request (e.g., product description).
3.e
Comments:
Has the organization making the Exclusion Request asserted that there is no capability in the United States to manufacture this type of aluminum product it requires? If "Yes" provide comments in the space below.
Has the Exclusion Requestor supported its assertion of product uniqueness with engineering and scientific data, or independent laboratory tests results?
3.f

Does your organization have technical data to disprove the assertions of the Exclusion Requestor? If "Yes" provide comments in the space below, or in attachments.
Comments:
Has the organization making this Objection Filing within the last two years attempted to sell, or successfully sold, the aluminum product described in the Exclusion Request to the exclusion requestor previously?

3.g

Does your organization manufacture a aluminum product similar to that cited in the Exclusion Request for which it has asked to Exclusion Requestor, within two years of the filing of the Exclusion Request, to perform a formal technical qualification to
determine equivalency in form, fit, function and performance?
Did the Exclusion Requestor accept or reject the request to perform a formal technical qualification?
Comments:

I have additional information to provide that is proprietary or otherwise business confidential that is relevant and necessary to this submission:

Instruction: This Objection Filing must be submitted by an organization official authorized to certify the document as being accurate and complete.
CERTIFICATION
The undersigned certifies that the information herein supplied in response to this questionnaire is complete and correct to the best of his/her knowledge. It is a criminal offense to willfully make a false statement or representation to any
department or agency of the United States Government as to any matter within its jurisdiction. [18 U.S.C. 1001 (1984 & SUPP. 1197)]
Company Name:
Name of Authorizing Official:
Phone Number:

Title of Authorizing Official
Email of Authorizing Official:

If the Point of Contact is different from the Authorizing Official provide point-of-contact information below.
Point-of-Contact Name:

Title

E-mail Address:

Phone Number
Paperwork Reduction Act Notice

Per the Paperwork Reduction Act of 1995, public reporting burden for this collection of information is estimated to average 4 hours per response, including the time to review instructions, search existing data sources, gather and maintain data needed, and complete and
review the collection of information. Send comments regarding this burden estimate or any other aspects of this collection of information, to 1401 Constitution Avenue, NW, HCHB 1093, Office of Technology Evaluation, Bureau of Industry and Security, U.S. Department of
Commerce, Washington, DC 20230 attn: 0694-0138. Commerce may not collect this information, and you are not required to respond; unless this OMB number is displayed.

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