Commerce exclusion request distorts aerosol market says CMI

Commerce exclusion grants on steel to a Japanese company harms livelihoods of US aerosol can manufacturing workers, said Can Manufacturers Institute President Robert Budway in a letter to Commerce Secretary Wilbur Ross.

Read his letter in full below:

Dear Secretary Ross:

We respectfully request a meeting with you as soon as possible to bring to your attention a grave matter harming the livelihoods of American aerosol can manufacturing workers. To our knowledge, the Department of Commerce granted 27 Section 232 exclusion requests for laminated tin-free steel to Daiwa Seikan Containers (DSC), a Japanese-owned manufacturer of aerosol cans that imports tariff-free Japanese steel into the United States. Those exclusion requests distorted the steel aerosol can market. They gave a competitive advantage to the Japanese-owned company compared to its American competitors that use standard tin mill steel, much of it American-made, to manufacture their steel aerosol cans. The difference between “laminated” and “standard” is that laminated tinplate is precoated during the manufacturing process, while standard tinplate is coated after its production and applied at a later stage. Tin mill steel is not produced in sufficient quantity or quality in the United States to meet the needs of the American can market.

We believe that this decision is not only unfair but contrary to the goals of the President’s Section 232 action in that it creates a significant artificial economic advantage in the aerosol can market for a foreign-owned firm.

This act by the Department of Commerce has directly led to the loss of over 135 high paying American jobs spread across multiple states and regions. Without immediate action, we believe additional job loss is imminent.

It also bears mentioning that, as DSC wins market share, the American steel manufacturers suffer. All of DSC’s success in the can market is fueled by Japanese steel. DSC’s American competitors, who lose sales to DSC, will buy less American steel. American steel companies who lose sales will need fewer workers and invest less in tin mill capacity, which is exactly the opposite outcome to the stated objective of the Section 232 actions.

DSC has three exclusion requests pending on the Docket. In the interest of fairness and protecting American workers we ask that you take one of the following actions (in order of preference):

  • Issue a categorical exclusion for all tin mill steel imported for aerosol applications.
  • If you intend to approve the DSC exclusion requests, also approve pending and future exclusion requests for “standard” tin mill products for aerosol applications from Ball Metalpack, Crown Cork & Seal, USA, Inc., and Mauser Packaging Solutions.
  • If you intend to deny exclusion requests for “standard” tin mill steel for aerosol applications, also deny DSC’s pending exclusion requests for laminated tin-free steel.

Any one of these options will level the playing field in the steel aerosol can market, but the first two are preferred. The third is less desirable because it will disadvantage all steel aerosol cans against other packaging media for aerosol products.

CMI requests that you meet with us to hear our views on this important matter. We look forward to your speedy response.

Robert Budway
Can Manufacturers Institute


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