Today, the SMA, along with a group of other steel industry associations and the United Steelworkers union, submitted the comments below to The Honorable Penny Pritzker on the proposed rule to extend the Steel Import Monitoring and Analysis (SIMA) System.


Dear Secretary Pritzker:

The undersigned steel industry groups and union (hereinafter referred to as “the industry”), on behalf of their members in the United States, respectfully submit these comments on the proposed rule to extend the Steel Import Monitoring and Analysis (SIMA) system as published by the U.S. Department of Commerce in the Federal Register on October 13, 2016 at 81 FR 70650-52.  These organizations represent companies and workers engaged in the overwhelming majority of steel production and distribution in the United States.

We thank the Department for the continued recognition of the importance and value of the SIMA system, and for proposing to extend it for an additional five years until March 21, 2022.  This program is a critical component of the U.S. government’s ability to closely monitor steel imports on a near real-time basis, and the industry has also found that SIMA provides significant benefits in the areas of timeliness and detail of steel import data that is published well in advance of the official reported statistics from the U.S. Census Bureau.

The SIMA system provides transparency for all interested parties, including the industry, government, importers and steel consumers.  It is especially critical given the current global overcapacity in steel that is fueling repeated surges in steel imports into the United States.  The SIMA program provides the only comprehensive means to ensure that all interested parties have access to steel import statistics at the earliest possible date.  In addition, it has been thoroughly demonstrated that, even in times of relative economic prosperity, there are dynamics in steel import flows that must be identified as early as possible.

There is no significant burden on the steel importing community to comply with the SIMA system.  That has been confirmed over the past 12 years of the current SIMA program and proposed extended form, and in the time prior to 2005 when SIMA was in its more basic format.

The industry believes that five years covers a significant span in the ever-changing and dynamic steel market.  However, the industry continues to strongly advocate for the creation of a permanent SIMA program, which would continue to be administered by the Department of Commerce.  This monitoring system has proven to be a highly effective tool in the observation and analysis of import trends.  We believe that, through the extension, this program will continue to provide benefits to the steel and trade communities and to other stakeholders involved in steel trade. The industry looks forward to working with the Department and the Administration to make SIMA a permanent program.

Thank you for the opportunity to offer comments and for your continued diligent attention to the trade concerns of the domestic steel industry, workers and communities across the country.


American Institute for Steel Construction

American Iron and Steel Institute

Cold Finished Steel Bar Institute

Committee on Pipe and Tube Imports

Metals Service Center Institute

Specialty Steel Industry of North America

Steel Manufacturers Association

United Steelworkers

Wire Rod Producers Coalition