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As comments in the ongoing Section 232 investigation into steel imports are being filed, we highlight two recent submissions that reflect the dichotomy of views on this trade issue. Both the American Iron and Steel Institute (AISI) and the National Foreign Trade Council (NFTC) filed comments with the Department of Commerce on May 31, 2017. AISI represents members of the steel industry that account for nearly 70 percent of U.S. steelmaking capacity. NFTC represents more than 200 U.S. companies with over $3 trillion in worldwide sales, including companies that rely on the steel industry.
AISI Comments:
&ldquo;[T]he U.S. steel industry has relied on our trade laws to seek to address the impact of unfairly traded steel imports in our market. While the antidumping and countervailing duty laws have provided some relief ... they leave openings for steel products not subject to orders to continue to surge into our market. ... The U.S. steel industry has been severely impacted by repeated surges in dumped and subsidized imports that have flooded the U.S. market in recent years. These surges are the result of foreign government interventionist policies in the steel sector that have fueled massive and growing global overcapacity in steel, particularly in China. If left unaddressed, this global steel crisis will threaten the very viability of the U.S. steel industry, and therefore will threaten the national security of the United States.&rdquo; AISI urges the Department of Commerce to use the Section 232 investigation to implement a &ldquo;more comprehensive and broad-based&rdquo; solution to safeguard national security. See <a href="https://www.thompsonhine.com/uploads/1345/doc/AISI_Comments_on_Section_232_National_Security_Investigation_of_Imports_of_Steel.pdf" target="_blank" rel="noopener">AISI&rsquo;s full comments</a>.
NFTC Comments:
&ldquo;We are ... extremely concerned about the notion of seeking to remedy unfair trade or global overcapacity through an overly broad definition of &lsquo;national security&rsquo; and the use of sweeping trade restrictions under Section 232. We do not believe that this is the proper role of a &lsquo;national security&rsquo; related remedy, which should be more narrowly focused on two considerations: (a) what specific national security needs are not being met; and (b) whether a targeted remedy that is not unduly disruptive to the rest of our national economy can ensure essential supply to our defense sector. If the focus is something different, such as to remedy unfair trade practices, we believe the proper course of action is for the industry to seek relief under the laws established for those purposes, such as the antidumping and countervailing duty laws. These laws have well-established procedural requirements for determining injury and assessing the appropriate scope and level of remedies.&rdquo; NFTC urges the Department of Commerce to balance the interests of steel consuming industries &ldquo;against the advisability of restrictions for national security reasons,&rdquo; the uncertainty that could be introduced if any &ldquo;broad-based&rdquo; or &ldquo;sweeping&rdquo; restrictions or trade barriers are created, and the potential for retaliation. See <a href="https://www.thompsonhine.com/uploads/1345/doc/NFTC_Comments_on_Section_232_Steel_Import_Investigation.pdf" target="_blank" rel="noopener">NFTC&rsquo;s full comments</a>.

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Industry Provides Comments on Section 232 Steel Import Investigation