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March 29, 2023

Import Monitoring Systems: Steel and Aluminum

Background
Over the years, several domestic manufacturing industries
have sought insulation from import competition-two of
particular note include steel and aluminum. Both industries
have formally established import monitoring systems-
regulatory programs administered by a federal agency that
monitor for certain imported goods. In the case of the steel
and aluminum import monitoring systems, both operate
under the authority of select provisions of the Census Act of
1930, as amended (13 U.S.C. §§301(a) and 302). These
systems monitor for imports of certain steel and aluminum
products to help anticipate import surges and changes in
price, as well as any potential impact on the domestic
industries.
The steel import monitoring system has been in effect for
over two decades, while the aluminum equivalent was
brought online in mid-2021. The Department of Commerce,
International Trade Administration (ITA), manages both
systems. Both of these import monitoring systems have the
potential to serve as a supplementary tool to existing trade
measures intended to help domestic producers remain
competitive relative to foreign producers.
Steel Import Monitoring System
The steel import monitoring system was first established
concurrently with the implementation of safeguard
actions-import measures designed to provide temporary
relief for a U.S. industry through the use of tariffs and/or
quotas-on certain steel products under select provisions of
the Trade Act of 1974 (19 U.S.C. §§2251-2253). These
temporary safeguard measures went into effect in March
2002, and the steel import monitoring system was activated
in February 2003. The Steel Import Monitoring and
Analysis (SIMA) system-the formal name of the
program-became codified under ITA in March 2005 and
has been in effect since.
The intent of the SIMA system is to monitor for import
surges through the implementation of an electronic-based
import licensing system. Such a system could provide an
early warning for import surges and price fluctuations of
certain steel products entering the United States. U.S.
Customs and Border Protection requires an ITA-issued
import license for imports of certain steel products prior to
their entry into the U.S. customs territory. In addition to the
licensing system, ITA maintains a web-based monitoring
tool that provides information on the trade of downstream
steel products and trends of U.S. and global steel trade.
Data obtained from the import licenses are aggregated and
incorporated into a website-the public SIMA monitor-
where the public can view and visualize data on a weekly
basis. Such information can provide up to eight weeks of
import data in advance of the release of official import

statistics from the U.S. Census Bureau. On balance, the
SIMA system comprises the import licensing system and
the public monitor.
In October 2020, the SIMA system underwent an extensive
modernization, in which the licensing system and public
monitor were updated. The update occurred as a result of
joint understandings announced in May 2019 between the
United States, Canada, and Mexico with respect to tariffs
imposed on certain steel and aluminum imports under
Section 232 of the Trade Expansion Act of 1962 (19 U.S.C.
§ 1862). Since May 2019, Canada and Mexico have been
exempt from such tariffs; several other countries face
modified restrictions, such as tariff-rate quotas in lieu of
tariffs.
One update of the SIMA system pertained to the license
application, which now requires applicants disclose
additional supply chain information, specifically the
country where the steel used in the manufacture of the
imported steel product was melted and poured (commonly
referred to as the country of melt and pour). According to
ITA, melt and pour refers to the original location where the
crude steel was produced in a furnace in its liquid state and
then processed into its first solid shape, being a
semifinished product (e.g., billets, blooms, or slabs) or a
finished mill product. For example, if the United States
imports certain steel products from a Mexican mill, the
country of origin may be Mexico, where the product was
manufactured; however, where the products were melted
and poured could include other countries, such as Brazil or
Russia, among others. SIMA's melt and pour dashboard
provides data breakouts by country of origin, as well as
country of melt and pour, expressed in quantity and value.
This information provides increased visibility on where
steel products are primarily sourced.
Information that importers or customs brokers must provide
in the import license includes the country of exportation,
expected date of export, expected date of import, expected
port of entry, and the date of application, among others.
U.S. importers have up to 60 days prior to the expected date
of entry to file an application, with the license being valid
for 75 days. ITA recommends importers apply for licenses
as far ahead of entry as possible to avoid delays. Doing so
could provide increased visibility from a regulatory
perspective to monitor for import surges.
Aluminum      Import Monitoring System
The Aluminum Import Monitoring and Analysis (AIM)
system has been in effect since June 2021 and is modeled
after the SIMA system. Like its steel equivalent, the AIM
system uses electronic-based licensing for certain imported
aluminum products and contributes to a website that details

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