Arlington, Va. – In a January 16, 2024, letter, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), the National Association of Home Builders, the American Trucking Associations, and the National Retail Federation joined a large coalition of trade associations and industry groups in urging U.S. Secretary of Commerce Gina Raimondo to narrow the scope of the International Trade Commission’s (ITC) ongoing antidumping duty (AD) and countervailing duty (CVD) investigations regarding aluminum extrusions. Responding to a request from its Aluminum Extrusion Task Force, AHRI spearheaded the effort, which is being undertaken in concert with the letter’s other signatories.

Aluminum extrusions are found in a variety of manufactured products, such as HVACR and water heating equipment, automotive engines, trailer components, RV components, retail shelving, etc., some of which contain thousands of individual aluminum extrusion components. AHRI raised concerns regarding the unusual scope proposal from the investigation petitioners [14 domestic aluminum extruders and one trade union] that would “impose duties on the value of the extruded inputs contained in downstream products (which the petitioners do not even produce or compete with) is deeply misguided and contrary to the interests of the United States.”

The practice is prohibited by the Tariff Act of 1930, and this interpretation has been upheld by the Court of International Trade as recently as 2023. Further, the current broad scope (to include downstream products and components) would force the importer to report the volume, value, and country of origin for every component or finished product covered. The letter argues that imposition of such duties would “be significantly detrimental to manufacturers, retailers, and consumers in the United States, while also adding tremendous burdens to the government agencies charged with collecting such duties.”

AHRI and its partner organizations call on Commerce to exclude downstream and further manufactured products that contain aluminum extrusions from the scope of its investigations to protect U.S manufacturers’ role in the global marketplace, maintain reasonable prices for U.S. consumers, and prevent unnecessary burdens on U.S. government agencies. AHRI plans to share these concerns during a meeting with Commerce later this week.

The full letter, including a complete list of the cosigning associations, is available here. For a more detailed version of AHRI’s scope arguments, see AHRI’s November 20, 2023, submission to the Department of Commerce, available here.