Requests for Exclusions to Section 232 National Security Adjustments of Imports of Steel and Aluminum

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

Exclusion Request - Aluminum

Requests for Exclusions to Section 232 National Security Adjustments of Imports of Steel and Aluminum

OMB: 0694-0139

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OMB Control Number: 0694-0139

Expiration Date: 3/31/2019

Request for Exclusion from Remedies: Section 232 National Security Investigation of Aluminum Imports
Exclusion Request Requirements: Only individuals or organizations operating in the United States that use aluminum products (e.g. slab, billets, ingots, extrusions, rod and bar, sheet and plate, foil, pipe and tube, castings and forgings, etc.) in business
activities (e.g., construction, manufacturing, supplying aluminum product to users) in the United States may submit an Exclusion Request. For an Exclusion Request to be considered, the Exclusion Requester must provide factual information on 1) the single
type of aluminum 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; 3) a full description of the properties of the aluminum product it seeks
to import, including chemical composition, dimensions, strength, toughness, ductility, magnetic permeability, surface finish, coatings, and other relevant data. Exclusion Requests must be submitted using this Excel-based document. Paper submissions will
not be accepted.
A separate Exclusion Request must be submitted on each distinct type and dimension of aluminum product to be imported. All applicable question blocks in the form must be completed for the Exclusion Request to be accepted. Exclusion Requests will be
denied if the applicant: 1) does not sufficiently address the specified reporting requirements; 2) cites the improper HTSUS code, or 3) provides incorrect product descriptions.
Organizations electing to attach supporting documents must provide these documents in PDF format and it must not exceed 25 pages. All information submitted in the Exclusion Request is subject to public disclosure. Do not provide sensitive Personally
Identifiable Information.
Organizations should upload their completed Exclusion Request pertaining to an aluminum product to www.regulations.gov under Docket Number BIS-2018-0002. An Exclusion Request may be submitted at any time. Processing of an Exclusion Request will
take approximately 90 business days. Notification of granted Exclusions will be posted on www.regulations.gov. For questions related directly to completing this form, contact BIS via email ([email protected]) or telephone (202-482-4757).

10-Digit Harmonized Tariff Schedule Code of the United States (HTSUS)
for the single aluminum product covered by this request:

1.a Identify the class of Aluminum product for which the Exclusion is sought:

(See https://www.usitc.gov/)

Requesting Organization Information

Importer of Record for Organization Requesting an Exclusion

Full Organization Legal Name

Full Organization Legal Name

Street Address

Street Address

City

City

State

State

Zip Code

Zip Code

Headquarters Country

Headquarters Country

Point of Contact Name

Point of Contact - Representative Name

Phone Number

Phone Number

1.b E-mail Address

E-mail Address

Web Site Address

Web Site Address
Parent Company of Requesting Organization

Requester's Authorized Representative/Agent (If applicable)

Full Organization Legal Name

Requester Point of Contact Name

Street Address

Point-of-Contact Organization

City

Country Location

State/Province

Phone Number

Zip Code/Postal Code

E-mail Address

Headquarters Country

Web Site Address

Web Site Address

Other Information

Does the parent organization hold ownership in (partially or completely), or is it otherwise
engaged as an: Aluminum Manufacturer; Aluminum Distributor; Aluminum Exporter or,
1.c Aluminum Importer? If "Yes" identify the activity.

If "Yes" - Identify
the organization

Identify the country where the
organization is headquartered

Comments:
1.d

Identify the primary type of aluminum activity of the Exclusion
Requester:

Total Requested Annual Exclusion Quantity in Kilograms (1 metric ton =
1,000 kilograms)

Comments:

Continued on Next Page

Page 1 of 5

Request for Exclusion from Remedies: Section 232 National Security Investigation of Aluminum Imports - Continued
2.a Average annual consumption for years 2015-2017 of the aluminum product that is subject of this Exclusion Request - Kilograms
Explain why your organization requires an Exclusion using 1) the drop-down box and 2) by providing written comments in the space provided below.
2.b
Comments:
2.c Identify the percentage of total aluminum product covered under this Exclusion Request not available from aluminum manufacturers in the United States:
2.d Estimate the number of days required to take delivery of the aluminum product covered by this Exclusion Request, from the time the purchase order is issued by your organization:
2.e Estimate the number of days required to manufacture the aluminum product covered by this Exclusion Request, from the time a binding purchase order is executed:
2.f. Estimate the number of days required to ship the aluminum product covered under this Exclusion Request, from the foreign port of departure to the Exclusion Requester's loading dock:
2.g Estimate the number of distinct shipments from the foreign port(s) of departure that will be needed for transporting to the United States the aluminum product subject to this Exclusion Request:
Identify the U.S. Destination Port(s) of Entry through which the aluminum product subject to this Exclusion Request would be transported:
2.h

Port 1

Port 2

Port 3

Port 4

Port 5

Port 6

Port 7

Is the organization making this Exclusion Request doing so on behalf of a non-U.S. aluminum producer that does not manufacture aluminum products in the United States?
Identify the country where the organization is headquartered

2.i If "Yes" identify the non-U.S. aluminum producer
Comments:

Exclusion Request Product Information
For this single Exclusion Request, provide a full, complete description of the product in the space provided below. * See explanation below.
The product for which an Exclusion is being requested is defined as follows:

2.j
* With regard to the product for which an Exclusion is requested, such a description must be limited to a single product. The description must be limited solely to physical properties (e.g., chemical requirements, mechanical requirements, dimensions, etc.)
and exact descriptive terms/phrases covering the product subject to the Exclusion Request (e.g., “hot-rolled,” “seamless pipe,” “suitable for use in boilers,” “longitudinally submerged arc welded,” etc.).
All such physical properties must be defined based on actual, rather than nominal, measurements; references to specific dimensions (e.g., “cross-sectional diameter of 5.50 mm”) or measurements (e.g., “yield strength of 300 MPa,” “carbon content 0.08%,”
etc.) will be interpreted as meaning the exact dimension or measurement. Ranges (e.g., “cross-sectional diameter falling within the range 5.35 mm and 5.65 mm,” “yield strength greater than or equal to 300 MPa,” “carbon content less than or equal to
0.15%, by weight,” etc.) are allowed. Where a range is needed, it should be identified based on the end points of the range (as in the examples above), rather than through references to absolute or percentage tolerances.

Comments:
Organization
Identify the standards organizations that have set specifications for the product type that is
the subject of this Exclusion Request, and provide the reference designation(s) for the
2.k
identified standards organization(s),
(e.g., ASTM A108-13):

Designation

Organization

1

Designation

3

2

4

Other (specify)

Organization

Designation

5
6

Other (specify)

Other (specify)

General Aluminum Product Description
Identify the classification and properties of the aluminum product covered under this Exclusion Request. Other classification or properties may be described in the Comment box below. (Select all that apply)
Slab

Blooms

Billets

Ingots

Fittings

Flat

Long

Beams

Semi-Finished

Pipe

Tube

Wire

Hot Rolled

Cold Rolled

Annealed

Plated

Electro-Plated

Galvanized

Electro-Galvanized

Zinc Plated

Aluminum
Plated

Lead Plated

Tin Plated

Painted

Varnished

Plasticized

Pickled

Other (Use
Comment Box)

2.l

Comment:
Continued on Next Page
Page 2 of 5

Request for Exclusion from Remedies: Section 232 National Security Investigation of Aluminum Imports - Continued
State the chemical composition of the specific aluminum product for which your organization seeks an Exclusion. 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

Nickel

Niobium

Nitrogen

Phosphorous

Selenium

Silicon

Sulfur

Tin

Titanium

Tungsten

Vanadium

Zinc

[Other - List
Below]

[Other - List
Below]

Minimum %
Maximum %

3.a
Minimum %
Maximum %

Comments:

Provide information on the single aluminum product that is the subject of this Exclusion Request: 1) dimensional information for the single aluminum product and a single size - not a range of products and or sizes
(e.g., 19 mm dia. rebar - not 19, 22, 25, and 29 mm.) A separate Exclusion Request must be submitted for each aluminum product by physical dimension; 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

Inside Diameter

Outside Diameter

Length

3.b

Toughness
(If Applicable)

Strength

Width

Height

Hardness
(specify method
Tensile
Yield
below - Brinnell,
Strength
Strength
Rockwell, Vickers,
Mega Pascal (MPa) Mega Pascal (MPa)
etc.)

Test Type

Drop-Weight Tear
Testing

Impact (Charpy)
Testing

Other
(specify type in
comment box)

Temperature (°C)
Minimum

Joules

Maximum

% Shear

Comments:

Provide the following information on the single aluminum product that is the subject of this Exclusion Request: 1) performance data for ductility and 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 %

Reduction
-in-Area %

Local Ductility
(If Applicable)

Hole Expansion %

Coating Type and Composition
(If Applicable)

Surface Finish
(If Applicable)

Bendability
(Bend
Radius/Sheet
Thickness
[millimeter]

Profilometer
- [SAE J911]

Coating Method

Coating Product
Name and
Abbreviation

Composition (e.g.,
Zn, Al, Si, Mg,
other intentionally
added elements or
alloys)

3.c
Minimum
Maximum
Select any additional processing methods used:

Other (specify)

Comments:

Continued on Next Page

Page 3 of 5

Weight
[Grams per Sq.
Meter]

Coating Thickness
[micrometers]

Request for Exclusion from Remedies: Section 232 National Security Investigation of Aluminum Imports - Continued
List the Commercial Name(s) of the single aluminum product that is the subject of this Exclusion Request.

4.a

Comments:
Identify the Aluminum Association code for the aluminum product that
is the subject of this Exclusion Request:

State below: 1) the application for the aluminum product (e.g., automotive, appliances, industrial products, structural, etc.) that is the subject of this Exclusion
Request, and 2) why similar aluminum products manufactured in the United States, if available, are not suitable.

4.b

If the Exclusion is needed to support U.S. national security requirements (critical infrastructure or national defense systems), provide a detailed description of the specific uses of this single aluminum product:
4.c

Identify the source countries for the single aluminum product for which the Exclusion is requested, the annual quantity to be supplied in kilograms, and the name of the current manufacturer(s) of the aluminum product. If this aluminum product is not
obtained directly from the manufacturer, identify the current supplier(s) and the country of the supplier(s). The Exclusion Request, if granted, will pertain solely to the identified supplier(s) listed in this form and the country of origin.
NOTE: Aluminum products encompassing more than one 10-digit HTSUS code must submit a separate Exclusion Request for each pertinent code.
Country of Origin
4.d

Country of Export

Exclusion Quantity

Current Manufacturer

Current Supplier
(if not obtained directly from manufacturer)

1
2
3
4
5
Product Availability Information

4.e

Does the requester possess knowledge of any domestic U.S. parties that currently manufacture the described aluminum product in the United States?
Comment:
Does the requester possess knowledge of any parties that currently manufacture the described aluminum product a country exempted from this tariff? If yes, identify the country or countries below.

4.f
Comment:
Is the requester aware of any manufacturers capable of producing a substitute for the aluminum product in the United States? If “Yes” provide supporting information (name and address) in the space below?
4.g
Comment:
Has the Exclusion requester attempted to qualify any aluminum manufacturer in the United States as a supplier of the aluminum product for that is the subject of this Exclusion Request in the past two years? If “Yes” provide supporting
information in the space below. Supporting documents must be submitted as a consolidated PDF file and may not exceed 25 pages.

4.h

1

5

2

6

3

7

4

8

Comment:
Continued on Next Page
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Request for Exclusion from Remedies: Section 232 National Security Investigation of Aluminum Imports - Continued
5.a

Has the Exclusion Requester attempted to purchase the described aluminum product that is the subject of this Exclusion Request, or a substitute, from a U.S. manufacturer in the past two years? If "Yes" identify the manufacturers,
addresses, and your points of contact at the U.S. aluminum manufacturing organizations in the space below.
Comment:

5.b

5.c

Has the Exclusion Requester had supply contracts, or have current contracts, with aluminum producers that manufacture in the United States the aluminum product identified in the Exclusion Request? If "Yes" identify the U.S. aluminum
manufacturers, addresses, and your points of contact at the U.S. manufacturing organizations in the space below.

Has the Exclusion Requester determined that there is no U.S. manufacturer that produces a near-equivalent aluminum product that would meet qualification requirements? If "Yes" identify in the space below the testing
standards/procedures employed to make that determination.
Comment:

5.d

In the last two years, has the requester purchased a substitute aluminum product manufactured in the United States in place of the aluminum product described in the Exclusion Request? If “Yes” provide supporting information in the space
below.
Comment:

5.e

Provide a detailed explanation as to how U.S. Customs and Border Protection (CBP) will be able to reasonably distinguish the aluminum product subject to the Exclusion Request at time of entry, without adding undue burden to their current entry system and
procedures.

Submission of Exclusion Requests: All Exclusion Requests must be fully completed and submitted to www.regulations.gov under Docket Number BIS-2018-0002 using this Microsoft Excel electronic form. All information submitted will be subject to public
disclosure, regardless of any statements by the requester that some information should be treated otherwise. Any further information required as a part of this Exclusion Request will be determined and requested solely by the U.S. Department of Commerce.
Submission of Supporting Documents (Attachments): Supporting attachments should be submitted to www.regulations.gov as PDF documents and must be posted to www.regulations.gov under Docket Number BIS-2018-0006. Total supporting submissions may
not exceed 25 pages.
Other Comments:
This request is for a product from a country subject to quantitative
limitations:

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

Instruction: This Exclusion Request must be signed by an organization official specifically 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 Offical:

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

Title
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: 0694-0139. Commerce may not collect this information, and you are not required to respond; unless this OMB number is displayed.

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