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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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The Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) has published an&nbsp;<a href="https://www.govinfo.gov/content/pkg/FR-2019-06-10/pdf/2019-12254.pdf" target="_blank" rel="noopener">Interim Final Rule</a> in the Federal Register announcing that it has developed a specific portal (i.e., the &lsquo;&lsquo;232 Exclusions Portal&rsquo;&rsquo;) for persons submitting exclusion requests, objections to exclusion requests, rebuttals and surrebuttals to replace the use of the federal rulemaking portal (<a href="http://www.regulations.gov" target="_blank" rel="noopener">http://www.regulations.gov</a>) and &ldquo;streamline the exclusions process while enhancing data integrity and quality controls.&rdquo; This interim final rule is effective June 13, 2019.
While BIS stated that <a href="http://regulations.gov" target="_blank" rel="noopener">regulations.gov</a> was readily available to quickly implement the steel and aluminum product exclusions process, &ldquo;the site was not easily adaptable to the 232 submissions process, particularly as it evolved into a multi-step system and required a significant amount of human data entry.&rdquo; The 232 Exclusions Portal will allow 232 submitters to view all exclusion request, objection, rebuttal and surrebuttal documents in one web-based system. To use the new portal,&nbsp;submitters must complete a web-based registration before&nbsp;submitting any documents. In addition, external parties will now be able to track submission deadlines in the same portal.
BIS will begin accepting new exclusion requests on the 232 Exclusions Portal on June 13, 2019 and will no longer accept new exclusion requests on <a href="http://regulations.gov" target="_blank" rel="noopener">regulations.gov</a>. However, objections, rebuttals and surrebuttals must always be filed on the system where the exclusion request was submitted, whether in <a href="http://www.regulations.gov/" target="_blank" rel="noopener">regulations.gov</a> or in the 232 Exclusions Portal. BIS has published a detailed <a href="https://www.commerce.gov/sites/default/files/2019-06/232%20Portal%20External%20User%20Guide%20Version%2006_10_2019_0.pdf" target="_blank" rel="noopener">User Guide</a> for the 232 Exclusions Portal so that parties can familiarize themselves with the operation of the portal before June 13, 2019.
BIS will accept public comment on this interim final rule until August 9, 2019. The comments should address whether BIS&rsquo;s efforts have addressed earlier concerns with the use of <a href="http://regulations.gov" target="_blank" rel="noopener">regulations.gov</a> for the 232 exclusions process, as well as comments on the 232 Exclusions Portal and the transition-related provisions. Specifically, BIS&nbsp;encourages comments on which 232 Exclusions Portal features are an improvement, as well&nbsp;as any&nbsp;areas of concern or suggestions for improvement. These comments should be filed via <a href="http://www.regulations.gov/" target="_blank" rel="noopener">regulations.gov</a> on docket number BIS-2019-0005.

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Department of Commerce to Launch Special Section 232 Steel and Aluminum Exclusion Request Portal