Department of Commerce
Department of Commerce requested public comments on a number of trade-related executive actions by the President.

AISI Submits Comments to Dept. of Commerce on Trade Deficits, Unfair Trade

May 10, 2017

WASHINGTON, D.C. – In response to requests from the Administration for public comments on a number of trade-related executive actions by the president, the American Iron and Steel Institute (AISI) today submitted input to the Department of Commerce on the causes of significant trade deficits and on China’s non-market economy (NME) status. Links to the full trade deficit comments can be found here, and the NME comments here.

In the trade deficits submission, Kevin Dempsey, AISI Senior Vice President for Public Policy, wrote that, “AISI’s principal concerns are foreign government unfair trade practices, including subsidies and other interventionist policies that have fueled repeated surges of dumped and subsidized steel imports into the United States and burden or restrict our exports of steel and steel-containing goods.

“Foreign unfair trade practices can act as barriers to U.S. exports and investment, restrict producers’ access to raw materials, and create an uneven playing field in international competition by unfairly advantaging certain countries’ manufacturers to the detriment of U.S. producers. These include export restrictions, import barriers, investment barriers, subsidies, anticompetitive conduct of state-owned enterprises and barriers in government procurement policies,” he said, citing recent reports by the Office of the U.S. Trade Representative.

“AISI believes changing these foreign unfair trade practices, while continuing to aggressively enforce our unfair trade remedy laws, will have a demonstrable effect on the U.S. trade deficit and will benefit the U.S. economy and workforce,” Dempsey said.

Dempsey said trade relief provided by some of the steel trade cases has somewhat reduced the volume of imports, but high volumes of steel continue to enter the U.S. market from countries not subject to AD/CVD relief, from countries where the AD/CVD relief has proven to be ineffective, and as a result of schemes by foreign producers and importers to evade the AD/CVD laws.

AISI’s comments included an analysis of the countries with the most significant trade deficits with the steel industry, including Vietnam -- with whom the U.S. had a trade deficit of $493 million in 2016, and China with whom the steel trade deficit exceeded three million net tons in 2014.

AISI also filed comments on China’s non-market economy status, and stated that “China remains very much a state-directed, nonmarket economy country, and does not meet the basic requirements set forth by U.S. statutes and the Department of Commerce for a functioning market economy.” The submission provided a detailed review of the current information related to the six statutory factors that would need to be met in order for China’s to be recognized as a market economy, and examples of how China has not fulfilled the requirements.


Contact: Lisa Harrison
202.452.7115 /

AISI serves as the voice of the North American steel industry in the public policy arena and advances the case for steel in the marketplace as the preferred material of choice. AISI also plays a lead role in the development and application of new steels and steelmaking technology. AISI is comprised of 19 member companies, including integrated and electric furnace steelmakers, and approximately 120 associate members who are suppliers to or customers of the steel industry. For more news about steel and its applications, view AISI's website at Follow AISI on Facebook or Twitter (@AISISteel).