Floor safes -- 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 safe model: UL listing number (UL 687 for burglary-resistant safes, UL 72 for fire-resistant), HTSUS subheading, physical dimensions and weight, security rating (Residential Security Container / RSC-I / RSC-II / TL-15 / TL-30), fire rating (30 minute, 1 hour, 2 hour), locking mechanism (mechanical dial, electronic keypad, biometric, redundant), and unit customs value. Include the UL certificate or listing directory extract for each model.

Document the current active domestic manufacturers of UL-listed floor safes and their published capacity + product-line positioning. As of 2026 the domestic UL-listed floor-safe manufacturing base is concentrated in four to five producers, and the low-end residential + small-business price segment (sub-$400 wholesale) is not served at commercial volume by any domestic producer. Reference the U.S. Census Bureau NAICS 332999 (all other miscellaneous fabricated metal product manufacturing) annual manufacturing statistics for domestic safe production data.

Floor safes are finished consumer and small-business durable goods, not a primary-metal derivative in the traditional Section 232 sense. The national-security nexus is limited: the specific product does not directly support defense-related manufacturing or defense supply chain resilience. State this directly in the inclusion rebuttal comment -- BIS has historically declined inclusion for products with weak or absent national-security nexus where the criterion (i) analysis of Federal Register notice 2026-15961 (connection to underlying steel/aluminum determination) is not met.

[Domestic suppliers contacted with dates] Contact each domestic UL-listed floor-safe manufacturer (identify by cross-reference to the UL Product iQ database at productiq.ulprospector.com and to the U.S. Commercial Service directory) with a written inquiry: can the manufacturer supply {{ANNUAL_QUANTITY}} units of the specific security-rating and fire-rating combination at the required delivery timeline at a wholesale price point competitive with the import? Document each response.

Quantify the 25% duty pass-through impact on [Annual customs value USD] of imports to the downstream small-business customer base (independent hardware stores, locksmiths, small-business office suppliers, residential security installers). Include: (i) 12-month import records; (ii) customer segment analysis showing what percentage of volume ships to small businesses purchasing life-safety-adjacent safes (firearm-storage, controlled-medication storage); (iii) evidence that the cost increase materially delays or eliminates otherwise-planned purchases.

Identify whether the specific UL-listed products are available from producers in any country not subject to the proposed Section 232 rate. Note that UL listing is required per U.S. safety regulation and cannot be waived -- alternate sourcing must include a producer already holding the required UL listings, not a producer capable of eventually obtaining them.

1. BIS Section 232 Exclusion Portal, historical determinations addressing finished chapter-83 hardware where domestic production cannot meet volume at competitive price points (regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 33-39 (primary-metal vs finished-good 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). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (i) national-security-nexus and (iii) domestic-capacity. 5. UL 687 (Burglary-Resistant Safes) and UL 72 (Tests for Fire Resistance of Record Protection Equipment) product-safety standards. 6. 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 floor safes and strong-boxes (HTSUS heading 8303) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for UL-listed floor safes below a de minimis dollar threshold, where domestic manufacturers cannot meet nationwide small-business and residential demand at the price points our small-business customer base can absorb. There is limited domestic production of UL-listed floor safes at the low-end price points that dominate the small-business (dental practices, veterinary clinics, small retail) segment. 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.