Dear Secretary Ross and Commissioner McAleenan:
I write to request that the Department of Commerce (DOC) and Customs and Border Protection (CBP) expedite the review of Novelis Inc.'s remaining product exclusion requests that involve imports from Canada. Novelis submitted nearly 900 product exclusion requests from the Section 232 aluminum tariffs that were implemented in March, 2018. Each of these requests have a direct impact on its Oswego, New York facility given its integrated supply chain with a Canadian facility. While most of these requests were approved, many have been backlogged for months and the recent government shutdown only caused further delays.
Novelis's Oswego facility represents its first U.S. operation and largest fabrication facility in North America. With over 1,100 employees, the facility produces more than a billion pounds of high-quality aluminum products each year used primarily by automotive, building and beverage can markets. Notably, between 2012 and 2016 Novelis invested more than $500 million to produce aluminum sheet for Ford's F-Series, F-150 trucks and Expedition. However, because the Oswego plant relies on a supply chain with a Novelis's facility in Kingston Canada, the company is paying significant tariffs as a result of the Section 232 aluminum order.
The supply chain between Novelis facilities in Oswego and Kingston are closely integrated due to the unique capabilities at each location, prior duty-free transactions and their proximity to one another. Product exclusions from Sec. 232 aluminum tariffs will help Novelis avoid a significant disruption to their supply chain. If they do not receive exclusions on imports from Kingston, production capacity at both locations could go down.
While I support targeted tariffs on heavily subsidized aluminum imports, from countries like China, broad-based tariffs on good actors from partner countries like Canada are negatively impacting companies like Novelis that have an integrated supply chains between North American facilities. In January, Congress passed into law a nearly $5 million increase in funding for the Section 232 exclusion process that should help speed up the current process. I understand that the recent government shutdown caused further delays and that pending requests that were objected to may require extra time to review and should be carefully evaluated. Again, to the extent possible, I urge the DOC to expedite Novelis's remaining exclusion requests that involve imports from Canada and CBP to work through any administrative issues in a timely manner. In addition, I am asking that you quickly expedite and approve all of Novelis's already approved exemption requests for a second year.
Thank you for your consideration of this important matter. Please don't hesitate to contact me or my staff should you have further questions.
Sincerely,