Dear Acting Commissioner Morgan:

On behalf of the American Primary Aluminum Association (APAA), I am writing to express our concerns and urge U.S. Customs and Border Patrol (CBP) to oppose efforts to grant relief to importers in the form of duty payment extensions and other flexibility mechanisms to defer or avoid payments. As of today, we understand that CBP will approve on a case by case basis additional days for payment of estimated duties, taxes and fees due to the coronavirus. When it comes to the Section 232 program, such actions will allow importers to game the system, result in import surges and pose a clear and present danger to U.S. economic and national security interests.

On behalf of America’s primary aluminum producers, we urge CPB not to implement policies that will undermine the Section 232 tariff program and harm American aluminum workers. We ask CBP to continue to fully implement President Trump’s Presidential Proclamation imposed under Section 232 of the Trade Expansion Act of 1962 on certain articles of aluminum and steel.

The APAA understands and recognizes that the coronavirus public health crisis is resulting in significant economic disruption and Congress is taking steps to protect vulnerable industries and unemployed workers. When it comes to American primary aluminum industry, any relief for importers will hurt domestic primary aluminum production and potentially threaten thousands of American aluminum jobs. Any “tax holiday” or relief will decimate the American aluminum industry which these tariffs are designed to save and support.

The Section 232 aluminum tariff program has been, and will continue to be, a lifeline for the domestic aluminum industry against foreign producers that do not operate on market principles. The minimal tariff imposed on foreign imports provides important relief for domestic production, and as a result of the current fragility of global supply chains, the United States cannot afford to allow important industries to be undermined by a government sanctioned 90-day tariff relief program. USTR has already put in place a process to deal with emergency regulations that have direct bearing on our nation’s ability to respond to the coronavirus crisis

We urge you to resist against implementing policies that undermine the Section 232 program, which is critically important for U.S. national security purposes and has allowed our America’s aluminum industry to start rebuilding.

Any tariff relief will have devastating consequences for the American industries these tariffs were designed to save and support. We strongly urge CBP not to consider the 90-day tariff relief and stand strong with America’s primary aluminum industry and American workers.

Sincerely,

Mark Duffy
Chief Executive Officer
American Primary Aluminum Association