U.S. Int'l. Trade Commision survey regarding Greenhouse Gas emissions in aluminum foundries

Posted By: Jerrod Weaver Government Affairs, Industry,

The U.S. International Trade Commission (USITC) is undertaking a new fact finding investigation that will assess the greenhouse gas (GHG) emissions intensity of steel and aluminum produced in the United States. As part of its investigation, the Commission will conduct a survey by issuing questionnaires to firms with facilities producing steel and aluminum products in the United States, whether U.S. or foreign owned, to collect data on their production of these goods and associated GHG emissions.

NFFS has learned that aluminum foundries have started to receive the initial notification letter from the USITC. The letter indicates that participation is mandatory under federal law (19 U.S.C. §1333(a)), and further indicates that foundries can expect the survey to be conducted in two separate parts. The first survey is a company-level questionnaire which asks for a point of contact for each facility your company owns that produced covered products (aluminum castings) in 2022. The second survey is a facility level survey which will be sent to each point of contact provided in the first response. The notification letter states that foundries can expect to receive the company-level questionnaire in late March or early April and that recipients will have 60 days to respond.

As requested by the USTR, the Commission will deliver the report containing the product category-level emissions intensity estimates no later than January 28, 2025. Additional information on the survey, covered products, and the specifics of USTR's request are available on the investigation website: https://www.usitc.gov/saemissions.

Recent question from a NFFS member foundry regarding the USITC GHG survey:

Red block letters reading "Q & A"Question: We received the initial letter from the US International Trade Commission regarding the Greenhouse Gas Emissions questionnaire mentioned in your November 27, 2023, article, "U.S. to study greenhouse gas emissions in steel and aluminum industries." I am assuming since we produce aluminum casting that we are required to participate in the study.  However, the question has been posed that since we do not import or export castings, this might not apply to us.  The document refers to HTS codes. Do you have any further information or insight as to whether or not this would be applicable?

Answer: You are not alone in receiving the USITC letter regarding Greenhouse Gas Emissions Intensities. It is our understanding that aluminum foundries will be required to participate in the survey because they MANUFACTURE aluminum castings, regardless of their status as an importer/exporter of aluminum castings.

Appendix B on the website www.usitc.gov/saemissions identifies the steel and aluminum product categories that are covered by the survey request. At the bottom of Appendix B, you will see note that aluminum castings are specifically identified as a relevant article (HTSUS) with a HTSUS code of 7616.99.5170. This reinforces our belief that domestic aluminum foundries will be included within the scope of the instrument and be required to participate.

One interesting fact is that when you review that Appendix B, the document includes aluminum castings within the ‘wrought products’ category and not under the unwrought products category that would be more technically correct. NFFS will inquire about the ITC definition of wrought products for clarification.