Aluminum Association: Aluminum import monitoring system needs reforms

The Aluminum Association, Arlington, Virginia, has released public comments in which it offers recommendations that it says will make the Commerce Department’s proposed “Aluminum Import Monitoring and Analysis” (AIM) system a valuable tool for the full value chain of the U.S. aluminum industry. The Aluminum Association says it has long supported the creation of such a system as a key trade enforcement mechanism.

“We appreciate the Commerce Department’s work to date to develop a monitoring system that will help government officials and the industry to better identify trends in trade flows and address misclassification, transshipment and evasion of duties,” says Aluminum Association President and CEO Tom Dobbins. “Now it’s critical that the department refine its initial proposal and establish a system that works for the entire U.S. aluminum industry value chain.”

As part of the license application for each shipment, the proposed rule would require filers to identify the country of origin for the import as well as the country where the product’s input aluminum material was “smelted and poured”—a term that is not defined in the proposed rule and for which consensus understanding is not currently available. Given the characteristics of the material and the operational realities of the aluminum industry, it would be an exceedingly large (and time-consuming) burden on suppliers and U.S. importers to meet this reporting requirement, the Aluminum Association says.

In its comments, the association strongly urges the department to modify the requirement to reflect real-world aluminum industry operations and to collaborate with industry stakeholders to determine if tracing input materials reasonably could be implemented to achieve the administration’s objectives.

The association proposed additional reforms to the proposed system, including:

• including all products in Chapter 76 within the scope of the AIM, particularly aluminum wire and cable products and scrap and secondary aluminum classified under HTS heading 7602;
• requiring filers to indicate whether the shipment is utilizing a granted 232 product exclusion on the license application, and require that the AIM website aggregate and report that information;
• minimizing the burden for reconciling estimated and declared prices in the AIM system;
• offering an alternative to the online application in case of system outage and coordinate with Customs & Border Patrol (CBP) to minimize the chance of disruption in the system; and
• reporting in aggregate on the AIM website at least some products at the 10-digit HTS level.