Heat-exchange-unit parts -- 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 component: OEM part number, OEM manufacturer name (Alfa Laval, Kelvion, SWEP, Danfoss, Modine, API Heat Transfer, Xylem, Chart Industries, etc.), HTSUS 8-10 digit subheading, parent heat-exchanger model and duty class, material composition (aluminum 3003/6061/6063 finstock and tube alloys; stainless 304L/316L for plates; copper-nickel 90/10 or 70/30 for marine tubing), ASME Section VIII pressure-vessel stamp reference where applicable, AHRI performance-rating certificate reference, and dimensional and surface-finish specifications. Attach OEM parts-catalog page, material test report format, and the ASME U-stamp or AHRI certification document.

OEM-parts capacity analysis: whether any U.S.-based heat-exchanger component manufacturer can produce the exact OEM-specified replacement part at the OEM's ASME or AHRI performance standard and material specification, not whether a generic heat-exchanger part is available. Contact each U.S.-based heat-exchanger OEM (Alfa Laval U.S., Modine Manufacturing, API Heat Transfer, Chart Industries, Xylem, Bell & Gossett, Armstrong International) and independent U.S.-based finstock and coil producers (Aerofin, Colmac Coil, Super Radiator Coils). Document each response. Reference U.S. Census Bureau NAICS 333415 (Air-Conditioning, Warm-Air Heating Equipment, and Commercial and Industrial Refrigeration Equipment Manufacturing) annual domestic-production statistics and the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) member and certification directories at ahrinet.org.

Heat-exchanger equipment supports commercial and industrial cooling and refrigeration infrastructure -- data-center cooling, food-cold-chain refrigeration, industrial process heat transfer, and building HVAC. Where the specific components service defense-related installations (DoD facilities, defense-critical data-center cooling, cold-chain logistics for defense medical supply), cite the specific program or contract. 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: heat-exchanger downtime cascades into food-safety, data-center-uptime, and industrial-process risk categories that operate against the underlying policy purpose. Reference the Department of Energy's Critical Materials Assessment 2023 discussion of copper-nickel and specialty aluminum in industrial heat transfer.

[Domestic suppliers contacted with dates] Written inquiry to each U.S.-based heat-exchanger OEM and independent finstock/coil producer identified above, plus to the AHRI Certification Program listings for the specific product category. For plate-and-frame components (Alfa Laval, SWEP, Kelvion, GEA), specify the exact plate pattern, gasket compound, and duty pressure -- generic 'plate heat exchanger' is not a sufficient inquiry. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments; Modine, Aerofin, and Colmac Coil are likely respondents for finstock and coil assemblies. Retain all correspondence in the inclusion-rebuttal file.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to downstream customers: HVAC service contractors, industrial process operators, cold-chain operators, and data-center facilities. Include: (i) 12-month CBP entry summaries; (ii) downstream customer segment analysis (percent to service-and-repair, percent to OEM-replacement, percent to new-installation); (iii) projected equipment-downtime multiplier when replacement parts run 12-16 additional weeks of lead time from re-sourcing effort; (iv) documented projection of downstream project pricing impact.

Identify whether OEM-specification heat-exchanger components are available from producers in any country not subject to the proposed Section 232 rate. Specialty heat-exchanger production is globally concentrated in a small number of source countries per OEM -- Sweden and Germany for plate-and-frame, Japan and Korea for brazed-aluminum finstock, and China for commodity coil production. Where alternate sourcing exists, document landed-cost comparison, ASME/AHRI qualification status of the alternate producer, and lead-time impact.

1. BIS Section 232 Exclusion Portal, historical determinations addressing OEM-specific precision heat-transfer components across HVAC and industrial-process categories (searchable public docket, regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 45-52 (methodology for evaluating specialty derivative components at the product-specification level). 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-domestic-industrial-capex basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (iii) domestic-capacity and (iv) downstream-employment. 5. ASME Boiler and Pressure Vessel Code, Section VIII, Division 1 (Rules for Construction of Pressure Vessels); AHRI Standard 400 (Performance Rating of Liquid to Liquid Heat Exchangers), AHRI Standard 410 (Forced-Circulation Air-Cooling and Air-Heating Coils). 6. U.S. Census Bureau NAICS 333415 domestic manufacturing statistics; Air-Conditioning, Heating, and Refrigeration Institute (AHRI) Certification Program annual directories.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of parts of heat-exchange units (HTSUS heading 8419.50 and parts subheading 8419.90) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for OEM-specific heat-exchanger replacement components -- brazed-aluminum finstock and coil assemblies, stainless-steel plate-and-frame gaskets and plates, copper-nickel tubing bundles, and specialty condenser/evaporator sub-assemblies -- sold under an OEM part number for HVAC and industrial process equipment already installed and in service in United States commercial, industrial, and refrigeration applications. Heat-exchanger replacement components are OEM-qualified against tight ASME Section VIII pressure-vessel or AHRI performance-rating specifications and cannot be substituted without a full requalification cycle. We request an 18-month exclusion 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.