Request for Comments on Significant Foreign Trade Barriers for the 2024 National Trade Estimate Report

Foreign trade barriers distort international trade and are extremely harmful to U.S. companies, especially those in the U.S. iron and steel industry. Such restrictions act as barriers to U.S. exports and investment, restrict U.S. producers' access to raw materials, and create an unlevel playing field in international competition by unfairly advantaging certain countries' manufacturers to the detriment of U.S. producers and suppliers. In its annual NTE Report, USTR identifies various foreign trade barriers, including export restrictions, import barriers, investment barriers, subsidies, anticompetitive conduct of state enterprises (SEs), and other forms of government intervention. The discussion below identifies trade restrictions in these categories for USTR's inclusion in its 2024 NTE Report, including those that are among the most concerning to AISI's member companies. Many of these barriers have been very harmful to domestic steelmakers. Around the world, governments regularly intervene in steel markets to bestow unfair competitive advantages on their domestic industries. In addition to the numerous export restrictions, import barriers, investment barriers, subsidies, and other forms of government intervention that benefit foreign producers at the expense of the American steel industry, AISI encourages USTR to monitor specifically the conferral of transnational subsidies, as well as the proliferation of subsidies in the name of environmental objectives. These subsidies have become increasingly prevalent in recent years, including among our trading partners, and it is critical that the U.S. government closely monitor their effect on the competitiveness of the U.S. steel industry. AISI also notes that the COVID-19 pandemic caused many countries to impose trade barriers and other measures to combat the health crisis and ensuing economic impacts. As highlighted below, several of these policies may remain in place and impact the ability of the U.S. steel industry to compete fairly and freely in global markets. As USTR monitors these and other issues, it should pay special attention to the barriers erected and advantages conferred in countries such Brazil, China, Korea, India, Indonesia, Russia, and Turkey. As detailed at length in this submission, the barriers imposed in these markets and the subsidies conferred to domestic producers in these countries are particularly problematic for the U.S. steel industry. Additionally, taken together, market distorting interventions, such as those described above, have created a serious global overcapacity crisis. According to the Organization for Economic Cooperation and Development (OECD) Steel Committee, global excess steel capacity remains substantial, totaling 612 million metric tons (MT) in 2023. Indeed, the OECD Steel Committee recently "voiced grave concerns about the deterioration in global steel market conditions that is currently being driven growing overcapacity, softening demand for steel, and government interventions in some economies that continue to distort steel markets." Overcapacity at such significant and growing levels has encouraged unfair foreign trade practices and subsidized imports that harm U.S. steelmakers. AISI appreciates that the U.S. government continues to recognize the challenges that the domestic steel industry faces due to the ongoing global steel excess capacity crisis and has maintained the remedy put in place under Section 232 of the Trade Expansion Act of 1962 (Section 232) on foreign steel imports to protect our national security. Any further exemptions from the Section 232 tariffs would severely undermine the effectiveness of this program. It is essential that the U.S. government maintains its commitment to vital domestic industries by acting to prevent injurious surges in imports driven by trade-distorting foreign government policies and practices.

Foreign trade barriers distort international trade and are extremely harmful to U.S. companies, especially those in the U.S. iron and steel industry. Such restrictions act as barriers to U.S. exports and investment, restrict U.S. producers' access to raw materials, and create an unloved playing field in international competition by unfairly advantaging certain countries' manufacturers to the detriment of U.S. producers and suppliers. In its annual NTE Report, USTR identifies various foreign trade barriers, including export restrictions, import barriers, investment barriers, subsidies, anticompetitive conduct of state enterprises (SEs), and other forms of government intervention. The discussion below identifies trade restrictions in these categories for USTR's inclusion in its 2024 NTE Report, including those that are among the most concerning to AISI's member companies. Many of these barriers have been very harmful to domestic steelmakers. Around the world, governments regularly intervene in steel markets to bestow unfair competitive advantages on their domestic industries. In addition to the numerous export restrictions, import barriers, investment barriers, subsidies, and other forms of government intervention that benefit foreign producers at the expense of the American steel industry, AISI encourages USTR to monitor specifically the conferral of transnational subsidies, as well as the proliferation of subsidies in the name of environmental objectives. These subsidies have become increasingly prevalent in recent years, including among our trading partners, and it is critical that the U.S. government closely monitor their effect on the competitiveness of the U.S. steel industry. AISI also notes that the COVID-19 pandemic caused many countries to impose trade barriers and other measures to combat the health crisis and ensuing economic impacts. As highlighted below, several of these policies may remain in place and impact the ability of the U.S. steel industry to compete fairly and freely in global markets. As USTR monitors these and other issues, it should pay special attention to the barriers erected and advantages conferred in countries such as Brazil, China, Korea, India, Indonesia, Russia, and Turkey. As detailed at length in this submission, the barriers imposed in these markets and the subsidies conferred to domestic producers in these countries are particularly problematic for the U.S. steel industry. Additionally, taken together, market distorting interventions, such as those described above, have created a serious global overcapacity crisis. According to the Organization for Economic Cooperation and Development (OECD) Steel Committee, global excess steel capacity remains substantial, totaling 612 million metric tons (MT) in 2023. Indeed, the OECD Steel Committee recently "voiced grave concerns about the deterioration in global steel market conditions that is currently being driven growing overcapacity, softening demand for steel, and government interventions in some economies that continue to distort steel markets." Overcapacity at such significant and growing levels has encouraged unfair foreign trade practices and subsidized imports that harm U.S. steelmakers. AISI appreciates that the U.S. government continues to recognize the challenges that the domestic steel industry faces due to the ongoing global steel excess capacity crisis and has maintained the remedy put in place under Section 232 of the Trade Expansion Act of 1962 (Section 232) on foreign steel imports to protect our national security. Any further exemptions from the Section 232 tariffs would severely undermine the effectiveness of this program. It is essential that the U.S. government maintains its commitment to vital domestic industries by acting to prevent injurious surges in imports driven by trade-distorting foreign government policies and practices.