Aluminum Import Monitoring System Necessary But Critical Program Reforms Needed | The Aluminum Association

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Aluminum Import Monitoring System Necessary But Critical Program Reforms Needed

June 1, 2020
The Aluminum Association today released public comments offering a number of recommendations to 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 has long supported the creation of such a system as a key trade enforcement mechanism. As noted in a letter from the bipartisan Congressional Aluminum Caucus last fall, an important monitoring system is critical to “help ensure U.S. aluminum producers can compete on a level playing field within North America.”
“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,” said Aluminum Association President & 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 there is not currently a consensus understanding. 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 association proposed additional reforms to the proposed system, including:
  • Include 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; 
  • Require 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; 
  • Minimize the burden for reconciling estimated and declared prices in the AIM system;
  • Offer 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;
  • Report in aggregate on the AIM website at least some products at the 10-digit HTS level.
About The Aluminum Association
The Aluminum Association represents aluminum production and jobs in the United States, ranging from primary production to value added products to recycling, as well as suppliers to the industry. The association is the industry’s leading voice, representing companies that make 70 percent of the aluminum and aluminum products shipped in North America. The association develops global standards, business intelligence, sustainability research and industry expertise for member companies, policymakers and the general public. The aluminum industry helps manufacturers produce sustainable and innovative products, including more fuel-efficient vehicles, recyclable packaging, greener buildings and modern electronics.  In the U.S., the aluminum industry supports $174 billion in economic activity and nearly 700,000 jobs. For more information visit, on Twitter @AluminumNews or at


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