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June 4, 2020, by CSUSTL Staff.

The Committee to Support U.S. Trade Laws (CSUSTL) submitted comments, on April 29, 2020, to the US Department of Commerce on the proposed rule to make changes to the Steel Import Monitoring and Analysis system (“SIMA”). CSUSTL strongly supports the changes to the regulations which would provide for a more effective and timely monitoring of import surges of specific steel products and aid in the prevention of transshipment of steel products.

CSUSTL supports SIMA’s collection of information identifying where the steel used to manufacture a downstream product imported into the United States was melted and poured. It is critical to have a mechanism that is in place to help determine whether such steel imports are manufactured from dumped and subsidized steel inputs.”

Under the rule, the SIMA system would be used by Commerce to help execute the Trump Administration’s May 17, 2019 agreements with Canada and Mexico to remove the duties on steel products imposed pursuant to Section 232 of the Trade Expansion Act of 1962. The three countries agreed to prevent the importation of steel articles that are unfairly subsidized or sold at dumped prices, to prevent the transshipment of steel articles, and to monitor for and avoid import surges.

Beyond identifying countries of melt and pour CSUSTL encourages Commerce to require U.S. importers to identify each country where subsequent processing of the steel has taken place. Doing so ensures transparency and confidence in the reported data because it requires traders to acquire mill test certificates for each processing stage.

CSUSTL notes that the SIMA system has operated under its current authority since March 11, 2005, and based on its past effectiveness, the group supports the decision to extend SIMA indefinitely.

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