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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On February 10, 2022, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) published in the Federal Register a <a href="https://www.govinfo.gov/content/pkg/FR-2022-02-10/pdf/2022-02870.pdf">Request for Public Comments</a> seeking comments on the Section 232 product exclusion process, including the responsiveness of the process to market demand and enhanced consultation with U.S. firms and labor organizations.&nbsp; The request for comments notes that the current average processing time for product exclusion requests that do not receive objections is 43 days and that the current average processing time for exclusion requests that receive objections is 98 days.&nbsp; BIS seeks comments on potential changes to the Section 232 forms and required information; the request, objection, rebuttal and surrebuttal process; the standards of review; criteria for general approved exclusions (GAEs); and the overall transparency of the process. &nbsp;Specific topics of interest include:
<ul>
<li>How to reduce the volume of submission errors and rejected filings in the Section 232 exclusions portal;</li>
<li>How to address the time for processing exclusion requests, including but not limited to reducing the length or type of attachments;</li>
<li>Requiring public summaries of any confidential business information in exclusion requests and objections, similar to the existing requirement for rebuttal and surrebuttals;</li>
<li>Requiring public disclosure of delivery times on the exclusion request and objection forms;</li>
<li>Requiring recent (i.e., from the last quarter or 90 days) evidence supporting claims made in a request or an objection;</li>
<li>Streamlining the online forms or otherwise reducing administrative burden; and</li>
<li>Assessing the GAEs&rsquo; criteria and identification of specific products.</li>
</ul>
This request for comments is pursuant to President Joseph Biden&rsquo;s <a href="https://www.govinfo.gov/content/pkg/FR-2022-01-03/pdf/2021-28516.pdf">Proclamation 10328</a> on December 27, 2021, which adjusted the imports of steel and aluminum into the United States based on the agreement reached with the European Union.&nbsp; See Update of <a href="https://www.thompsonhinesmartrade.com/2021/12/president-biden-issues-proclamations-adjusting-imports-of-steel-and-aluminum-into-the-united-states/">December 29, 2022</a>.
Interested parties must submit any comments no later than March 28, 2022 via the Federal eRulemaking Portal at <a href="https://www.regulations.gov">https://www.regulations.gov</a> on docket number BIS&ndash;2021&ndash;0042.&nbsp; Within 60 days of the close of the comment period, BIS will issue a proposed regulation revising the product exclusion process as needed based upon the consideration of such comments.

BIS Seeks Comments on Section 232 Steel and Aluminum Product Exclusion Process

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