USITC Issues 332 to Assess Greenhouse Gas Emissions: Where Sustainability Meets Trade Policy

 

The U.S. International Trade Commission (USITC) is undertaking a new factfinding investigation that will assess the greenhouse gas (GHG) emissions intensity of steel and aluminum produced in the United States.  As part of its investigation, the Commission will conduct a survey by issuing questionnaires to firms with facilities producing steel and aluminum in the United States, whether U.S. or foreign owned, to collect data on their production of these goods and associated GHG emissions.

This survey will be mailed to all extruders in the United States.  The announcement made by the ITC on July 6, 2023, can be accessed here. 

As requested, the USITC, an independent, nonpartisan federal agency, will prepare a public report.  The report will provide, to the extent practicable:

1. GHG emissions intensity estimates of steel and aluminum produced in the United States by product category and production stage in 2022, with data on Scope 1, 2, and 3 emissions defined as:
2. Scope 1: Direct emissions from the facility’s owned or controlled sources.
3. Scope 2: Indirect emissions from the generation of the facility’s purchased energy, including electricity, steam, heat, or cooling.
4. Certain Scope 3 emissions: Emissions associated with material and resource inputs for the production of steel and aluminum.
5. A description of the methodologies used to collect relevant information and to analyze product-specific GHG emissions intensities for the range of steel and aluminum products made in the United States.

The investigation serves several purposes.  First, it informs our government of our ability to collect such data, and what our current footprint reveals.  Secondly, it sets a baseline for data collection and the actual results.  This pull of data will show the government we know our GHG output, and what our contribution is today.  That leads to the third benefit, promote policies that drive that number down!  

Once the government learns where we are as an industry, I suspect targets may be initiated with the purpose of reducing GHG emissions.  Lastly, this sets the stage for International trade agreements based on the carbon content of the aluminum we buy, and the extrusions we make.  The vision is to replace the 232 with a new program that imposes tariffs on aluminum products covered by the original 232 that places tariffs on imports and exports of aluminum products, including extrusions.  It should be noted that in the proposed trade side of this initiative, non-market economies would also be assessed duties regardless of carbon content.

This is important and something in which we must be engaged.  It is likely that everything from definitions, the role of scrap, how this program would be managed for compliance with bad actors, and so much more will be addressed.  We are working now to get a webinar set up for more details.

Elsewhere, our China case was fairly quiet this month.  We are preparing for key court dates involving the KingTom decision and the door threshold case.  We have essentially wrapped up the administrative review for the year and look forward to the final results. 

The world of trade is heating up.  Look for announcements and webinars in the coming weeks to learn how the AEC and its members plan to address this critical concern.  Thank you for your continued support!