Fire extinguishers -- 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 extinguisher model: HTSUS subheading (typically 8424.10.0000 for fire extinguishers), UL listing number and standard (UL 299 for dry-chemical, UL 154 for CO2, UL 626 for water, UL 711 for classifications and rating), classification and rating (e.g., 2A:10B:C, 40B:C), agent type and quantity, cylinder material (steel per DOT 4BW/4BA specification, or aluminum per DOT 3AL), pressure rating, service pressure and hydrostatic test pressure, and unit customs value. Include the UL certificate, the Department of Transportation cylinder-specification stamp reference, and the manufacturer's NFPA 10-compatible service and recharge documentation.

The active domestic UL-listed fire-extinguisher manufacturing base is documented in the UL Product iQ database (productiq.ulprospector.com) and includes Amerex Corporation, Ansul (Johnson Controls), Badger Fire Protection, Kidde (Carrier), and Buckeye Fire Equipment. Document contact with each producer at the specific UL classification, DOT cylinder specification, agent type, and annual quantity requested. Reference U.S. Census Bureau NAICS 332999 (All Other Miscellaneous Fabricated Metal Product Manufacturing) and the Fire Equipment Manufacturers' Association (femalifesafety.org) member directory to confirm the domestic supplier universe is fully canvassed. BIS methodology evaluates capacity at the specific UL-listing and DOT-specification level, not at aggregate 'fire extinguisher' level.

Fire extinguishers support building life-safety and directly protect Federal facilities, DoD installations, veteran healthcare facilities, and Department of Homeland Security critical-infrastructure buildings covered by NFPA 10 code adoption. Where the exclusion covers extinguishers destined for GSA-scheduled distribution, defense installations, or federal-building service contracts, cite the specific contract number or GSA schedule. 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: a 25 percent duty on life-safety extinguishers directly delays or displaces code-mandated installations, operating against the underlying policy purpose. NFPA 10 replacement and inspection cadence is fixed by code -- demand cannot be deferred.

[Domestic suppliers contacted with dates] Written inquiry to each domestic UL-listed manufacturer above, plus to the Fire Equipment Manufacturers' Association (femalifesafety.org) directory of North American producers. Include the specific UL classification and DOT cylinder specification -- 'fire extinguisher' at the aggregate level is not a sufficient inquiry. For Class K wet-chemical extinguishers (commercial-kitchen life-safety, code-mandated by NFPA 96), the domestic manufacturing base is even more concentrated and lead times run 12-16 weeks in normal conditions. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments; Amerex and Ansul are the most likely objectors and any specification-match claims they make should be pre-addressed with UL-listing-number-level specificity.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to the downstream customer base: fire-protection distributors, building-service contractors, restaurant-equipment dealers, and municipal fire-marshal-directed retrofit programs. Include: (i) 12-month CBP entry summaries; (ii) downstream customer segment breakdown (percent to fire-protection distributors, percent to restaurant kitchen retrofits, percent to multi-family housing property managers); (iii) projected impact on NFPA 10 code-compliance rates in the served markets if the pass-through delays scheduled six-year recharge and twelve-year hydrostatic-test replacement cycles.

Identify whether UL-listed, DOT-cylinder-specified extinguishers at the required classification are available from producers in any country not subject to the proposed Section 232 rate. Note that UL listing and DOT cylinder specification are non-waivable U.S. safety and transportation requirements -- an alternate producer must already hold the required UL listings and DOT approvals at the specific classification, not merely be capable of eventually obtaining them. This narrows alternate sourcing meaningfully in most fire-extinguisher categories.

1. BIS Section 232 Exclusion Portal, historical determinations addressing life-safety hardware categories where UL listing and DOT specification requirements narrowed the domestic-supplier universe (searchable public docket, regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 33-39 (finished-good vs primary-metal distinction). 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-policy-purpose basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (i) national-security-nexus and (iii) domestic-capacity. 5. UL 299 (Dry Chemical Fire Extinguishers), UL 154 (Carbon-Dioxide Fire Extinguishers), UL 626 (Water Fire Extinguishers), UL 711 (Rating and Fire Testing) product-safety standards; NFPA 10 (Standard for Portable Fire Extinguishers), NFPA 96 (Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations). 6. 49 CFR § 178 (DOT Specifications for Packagings), sub-specifications 4BA, 4BW, and 3AL for fire-extinguisher pressure cylinders; U.S. Census Bureau NAICS 332999 domestic manufacturing statistics.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of fire extinguishers, charged or not (HTSUS heading 8424) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for UL-listed portable fire extinguishers (ABC dry-chemical, CO2, Class K wet-chemical, water-mist) supplied for life-safety code compliance in commercial buildings, restaurants, schools, healthcare facilities, and multi-family housing. Fire extinguishers are a life-safety product subject to UL 299, UL 154, UL 626, and UL 2129 standards and to NFPA 10 code-mandated placement, inspection, and recharge requirements. The domestic UL-listed fire-extinguisher manufacturing base is concentrated and does not currently produce the full model range at the volumes required to serve the annual NFPA 10 replacement and new-installation cycle. A 25 percent duty applied to this life-safety category directly delays or displaces code-mandated installations. 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.