Agricultural trailers -- Section 232 Inclusion Rebuttal Comment Template

Company: [Company legal name] Address: [Company registered address] EIN: [Federal Employer Identification Number] Primary contact: [Primary contact name], [Primary contact title] Email: [Primary contact email] · Phone: [Primary contact phone] Filed via regulations.gov Docket BIS-2026-15961 pursuant to the FR 2026-15961 public-comment framework.

HTSUS subheading: [HTSUS 8-10 digit subheading] [Detailed product description] Provide for each unit: HTSUS 8-10 digit subheading (8716.20.0000 for self-loading/self-unloading agricultural trailers is the correct primary classification; 8716.39 subheadings apply for other agricultural transport trailers), trailer type (grain cart, silage wagon, forage box, manure spreader, bale trailer), rated capacity in bushels or cubic feet, unloading configuration (auger, apron chain, side-discharge, rear-discharge), OEM manufacturer, hitch class and tow-vehicle compatibility, and unit customs value. Include the OEM technical data sheet, the ASABE (American Society of Agricultural and Biological Engineers) standard compliance documentation, and the Farm Machinery Manufacturers Association classification.

Document each U.S.-based agricultural-trailer manufacturer at the specific trailer class. The domestic base includes Kinze Manufacturing (grain carts), Brent (grain carts, silage wagons), Unverferth Manufacturing (grain carts, seed tenders), J&M Manufacturing, Killbros/Parker (grain carts, gravity wagons), Meyer Manufacturing (silage wagons, spreaders), Kuhn North America (spreaders, mixers), and H&S Manufacturing. Contact each producer at the specific trailer class, capacity, and configuration. Reference U.S. Census Bureau NAICS 333111 (Farm Machinery and Equipment Manufacturing) domestic-production statistics and the Association of Equipment Manufacturers (AEM) agricultural-machinery member directory. Historic BIS methodology evaluates capacity at the specific trailer-class level, not the aggregate 'agricultural trailer' level.

Agricultural equipment supports U.S. domestic food-supply resilience -- a Department of Agriculture and Department of Defense joint concern under the National Defense Strategy 2022 food-security appendix and the Defense Production Act Title III food-and-agriculture-sector designations. Where the specific units serve commercial row-crop or dairy operations under USDA-designated critical-infrastructure classification, cite the sector designation. For commercial-only end use, base the request on criterion (v) 'other information the commenter believes relevant' of Federal Register notice 2026-15961's public-comment invitation: agricultural-equipment fleet-capacity constraints directly cascade into harvest-throughput risk, which the Section 232 policy does not intend to disadvantage.

[Domestic suppliers contacted with dates] Written inquiry to each U.S.-based agricultural-trailer manufacturer identified through the Association of Equipment Manufacturers directory (aem.org), the Farm Equipment Manufacturers Association (farmequip.org), and the U.S. Commercial Service agricultural-machinery supplier database. Include the specific trailer class, capacity, and delivery timeline -- generic 'agricultural trailer' is not a sufficient inquiry, and Kinze/Brent/Unverferth compete only at the grain-cart class while H&S and Meyer compete at the silage-wagon class. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to downstream customers: independent farm-implement dealers, cooperative equipment programs, and direct-to-farm sales channels. Include: (i) 12-month CBP entry records; (ii) downstream customer segment analysis (percent to row-crop operators, percent to dairy operators, percent to custom-harvest fleets); (iii) documented projection of equipment replacement-cycle deferral if the pass-through delays scheduled 15-20 year fleet rotation; (iv) harvest-throughput-cost impact projection for regions in which fleet-capacity is constrained.

The global agricultural-trailer production base includes Canada (Bergmann, Kongskilde), Germany (Krone, Fliegl, Bergmann Maschinen), and Poland (Metal-Fach). Document contact with alternate-country producers at the specific trailer class and quantity. Note that farm-implement dealers typically standardize on a specific OEM to control parts inventory and dealer-service capacity -- OEM substitution has a real dealer-integration cost.

1. BIS Section 232 Exclusion Portal, historical determinations addressing agricultural-equipment derivative articles where U.S. capacity at the specific class was insufficient (searchable public docket, regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 39-47 (downstream capital-goods sector analysis including agricultural equipment). 3. the public comment mechanism established by Federal Register notice 2026-15961 (August 6, 2026), operative under the notice-and-comment rulemaking framework of 5 U.S.C. § 553(c); criterion (v) 'other information the commenter believes relevant' of Federal Register notice 2026-15961's public-comment invitation (adverse-effect-on-food-supply-chain basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (iii) domestic-capacity and (iv) downstream-employment. 5. Defense Production Act Title III (50 U.S.C. § 4501 et seq.) food-and-agriculture-sector designations; USDA critical-infrastructure sector designation under Presidential Policy Directive 21. 6. U.S. Census Bureau NAICS 333111 domestic manufacturing statistics; Association of Equipment Manufacturers (AEM) agricultural-machinery annual industry statistics.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of self-loading or self-unloading trailers for agricultural purposes (HTSUS heading 8716, subheadings 8716.20 and related 8716.39 categories for other agricultural transport trailers) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for grain carts, silage wagons, forage boxes, manure spreaders, and self-unloading agricultural trailers used in commercial row-crop and dairy operations. These units are typically fabricated from galvanized structural steel with hydraulic drivetrain and auger/conveyor components; the primary-metal share of finished-good value ranges 40-55 percent. The domestic agricultural-trailer manufacturing base is regionally concentrated and does not currently produce all specialty categories at the volumes required by U.S. row-crop and dairy operations. For the reasons set forth below, [Company legal name] respectfully urges BIS to decline inclusion of these subheadings in the final Section 232 derivative-article coverage. Should BIS proceed with inclusion notwithstanding this comment, [Company legal name] requests that BIS incorporate a 24-month transition and adjustment period covering the specific HTSUS subheadings identified below. Requested transition-and-adjustment period if BIS proceeds with inclusion: [Requested transition-and-adjustment period if BIS proceeds with inclusion - typically 12 months] months.

Pursuant to 18 U.S.C. § 1001 (false statements to a federal agency) and the identification requirements of 5 U.S.C. § 553(c), I attest that the statements in this comment are true and accurate to the best of my knowledge, and that I am authorized to submit this comment on behalf of [Company legal name]. _________________________________ [Primary contact name], [Primary contact title] [Company legal name] [Primary contact email] · [Primary contact phone] Submitted via regulations.gov Docket BIS-2026-15961: 2026-08-26 --- **Draft Status: v0 -- attorney-review-pending.** This template was auto-generated by TariffWatch from Federal Register notice 2026-15961, Presidential Proclamations 10895 and 10896 (Feb 10, 2025 -- terminating the 15 CFR § 705.5 exclusion-request process), and publicly available BIS Section 232 rulemaking materials. Not legal advice, not customs classification advice under 19 CFR 111. Consult qualified counsel or a licensed customs broker before submitting to regulations.gov Docket BIS-2026-15961. Every substantive claim in this request that is factual to your business -- HTSUS subheading, annual quantity, annual customs value, cost-impact projections, sourcing country, domestic-supplier contacts -- must be verified by the submitter before filing. TariffWatch (Digital Empire Holdings LLC) makes no representation as to the sufficiency of this request for any specific regulatory outcome.