SPECIAL REPORT: Steel and aluminum tariff exclusion requests by congressional district

On March 8, following recommendations by the Commerce Department, President Trump imposed 25 percent tariffs on steel imports and 10 percent tariffs on aluminum imports. TradeVistas contributors Christine McDaniel and Danielle Parks of the Mercatus Center pulled data from the government website regulations.gov to create two interactive maps illustrating where requests for steel and aluminum have been filed by U.S. producers who use these metals as inputs in their production processes. As of October 11, 30,916 steel tariff exclusion requests and 3,933 aluminum tariff exclusion requests were available on regulations.gov.

In total, there have been 34,849 exclusion requests filed by 807 firms in 292 congressional districts. This is a 34.9 percent increase just since mid-August. At the same time, the Commerce Department has a process for steel and aluminum manufacturers in the United States to file an objection to exclusion requests. As of October 11, 14,751 objections have been filed (14,356 for steel and 395 for aluminum). Our maps are now updated to include the number of objections filed by congressional district.

Download and share our timeline on the steel and aluminum tariff exclusion request process. Read company stories about the impact of the tariffs. As the exclusion request process remains open for new filings, we will regularly update the data maps on this site.

Explore three different maps. Map 1 provides data on steel exclusion requests. Map 2 provides data on aluminum exclusion requests. Map 3 illustrates the share of employment in manufacturing in each congressional district. The data will be updated frequently.

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Who is Filing for Tariff Relief and How is the Exclusion Request Process Working?

By Christine McDaniel and Danielle Parks

 

Industry v. Industry

On March 8, following recommendations by the Commerce Department, President Trump imposed 25 percent tariffs on steel imports and 10 percent tariffs on aluminum imports. A tariff is a tax on imported goods, paid for ultimately by consumers and manufacturers that buy these materials for their own production processes. The tariffs afford protection U.S. domestic steel and aluminum makers to raise their prices as well. While U.S. steel and aluminum manufacturers are benefiting from these higher prices, U.S. manufacturers that use steel and aluminum in their production process are negatively affected by higher input costs. We can know where these higher costs are resonating by examining the list of companies that are filing requests for tariff relief, and we have matched them to their congressional district.

The Exclusion Process

U.S .manufacturers that use steel or aluminum in their production process may request for their purchases of these metals to be excluded from the tariff. The Bureau of Industry and Security (BIS) of the Commerce Department administers this tariff exclusion process. Firms may file a request on regulations.gov under separate dockets for steel (BIS-2018-0006) and aluminum (BIS-2018-0002).

The exclusion requests are generally granted “if there is no domestic availability and there are no overriding national security concerns with regard to the specific products,” according to a press release by the Commerce Department. Commerce Secretary Ross testified, however, that if a U.S. steel or aluminum producer can produce the product listed in the exclusion request, or might be able to make it if they were to ramp up future production, then Commerce would likely deny the request.

Companies’ Experience Filing Requests

Firms are required to submit a separate exclusion request for each distinct type and dimension of the imported product. The forms also require specific information such as the chemical composition, strength, toughness, list of entry ports, specific tariff code, expected amount for the year, etc. If the form has missing or incorrect information, then it will be denied. Firms or individuals can submit an objection to each exclusion request within 30 days of a submission, and BIS aims to process requests 60 days following an objection (so the entire process should take 90 days). As of September 11, the Commerce Department is allowing firms to refute the exclusion requests by filing a rebuttal within seven days of each objection submitted against the exclusion request. The steel and aluminum manufacturing firm that filed the objection can in turn submit a “surrebuttal” within seven days.

At a recent congressional hearing, U.S. companies revealed their experiences with the exclusion process. A broad range of U.S. firms testified that navigating the process was overly burdensome, can take more than 90 days, and often requires hiring outside lawyers.

Overloading the System

The two graphs below show, as of August 26, 2018, the rapid accumulation of these requests. A deadline has not yet been set, and firms continue to submit new exclusion requests.

Number of steel requests August 30
Number of alum tariff requests Aug 30
Who Filed in My District?

Detailed data on individual exclusion requests filed to date are available at regulations.gov. We aggregated the submissions by congressional district and find that as of August 17, 2018, U.S. manufacturers have filed 23,505 steel aluminum exclusion requests and 2,304 aluminum exclusion requests. Interactive Map 1 and Map 2 show the number of filings by congressional district.

The steel exclusion requests span 239 congressional districts and 45 states plus Puerto Rico. The 7th district in California had the highest number of firms filing—18 firms in that one district alone. The most exclusion requests within any one congressional district occurred in the Illinois 6th — 2,595 requests filed by four firms.

The aluminum exclusion requests span 87 congressional districts and 28 states plus Puerto Rico. The Illinois 5th district had the highest number of aluminum exclusion requests — 665, filed by two firms. Ohio’s 1st district had the second highest number of filings — 334 exclusion requests by one firm.

Which Manufacturing Workers are Affected?

The states with the most exclusion requests filed are also among the states with the most manufacturing workers: Illinois, California, Michigan, Texas, Ohio, South Carolina, and Indiana. This is further confirmed by the U.S. Census data displayed in Map 3: Manufacturing share of employment by congressional district.

manufacturing employment and tariff exclusions by state

The data provided above show that 25,809 tariff exclusion requests for steel and aluminum have been filed across the country, in 45 states plus Puerto Rico and in 264 congressional districts.

Each exclusion request represents a U.S. manufacturer that needs access to competitively priced aluminum and steel globally to remain competitive domestically and in their export markets.

The 25 percent tariff on steel and 10 percent tariff on aluminum have translated into higher prices for those metals for U.S. manufacturers. Most manufacturers are small- or medium-sized firms that operate on thin margins and lack the ability to pass costs on to their customers. As a result, many U.S. manufacturers now face some very tough decisions. Some may opt to import more finished goods to keep down average costs or move production offshore where they can access raw materials at competitive prices.

The exclusion process remains open, and we will update these data as they become available.

Christine McDaniel and Danielle Parks are with the Mercatus Center at George Mason University.

Company Stories

How four American companies are trying to cope with the tariffs.

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