Written Comments by Representatives of the Domestic Steel Industry
September 24, 2004
Director for Industry Support and Analysis
Import Administration, Room 3713
U.S. Department of Commerce
14th & Constitution Ave., NW
Washington, DC 20230
Request for Comments on Steel Import Monitoring and Analysis System
Dear Mr. Parkhill:
These comments are filed on behalf of the U.S. members of the American Iron and Steel Institute, the
Cold Finished Steel Bar Institute, the Committee on Pipe and Tube Imports, the Specialty Steel Industry
of North America, the Steel Manufacturers Association, the Steel Tube Institute of North America and the
United Steelworkers of America (“domestic industry”). These organizations represent virtually all major
U.S. producers of steel products and their employees.
A critical element to help ensure fair trade in steel in the post-Section 201 period is the continuation of the
Steel Import Monitoring and Analysis (SIMA) system. The Department of Commerce (DOC) published a
proposed rule and request for public comments in the Federal Register of August 25, 2004 (69 FR 52211).
The domestic industry submits these comments in response to that notice.
The volatility in world steel markets makes it essential that the government and industry have access to
the most up-to-date and accurate information possible. For the first seven months of this year as compared
to 2003, both total and finished steel imports have increased by 33 percent. Demand for steel in China
remains a major wildcard affecting world markets, and Russia -- no longer subject to the "Comprehensive
Steel Agreement” -- has dramatically increased shipments to the United States.
Given that the SIMA statistics are essentially the same information already published with several weeks
delay by the Bureau of the Census in its official import data, it is easy to envision strong support for the
expedited collection and release of these data. It is critical