Mobile lifting frames on tires and straddle carriers -- 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 (8426.12.0000), unit type (straddle carrier, rubber-tired gantry, or reach stacker), rated safe-working-load in metric tons, span and lift height, propulsion type (diesel-electric, hybrid, battery-electric), OEM manufacturer (Kalmar (Cargotec), Konecranes, Liebherr, ZPMC, Sany, Terex), unit customs value, and destination terminal or facility. Include the OEM technical data sheet, the CE marking or equivalent EU Machinery Directive documentation, and any container-terminal-operator specification documents to which the unit was built.

Document each domestic manufacturer of container-handling straddle carriers, RTGs, and reach stackers -- the U.S. domestic manufacturing base for this category is effectively zero as of 2026. Terex Corporation historically supplied reach stackers from U.S. facilities; that production line has been consolidated to non-U.S. operations. Contact any remaining U.S.-based container-handling-equipment manufacturers, Konecranes' U.S. Springfield facility, and any recent Cargotec/Kalmar U.S. sourcing announcements. Reference U.S. Census Bureau NAICS 333923 (Overhead Traveling Crane, Hoist, and Monorail System Manufacturing) domestic-production statistics and the American Association of Port Authorities (aapa-ports.org) equipment-supplier directory. Historic BIS methodology confirms that a documented zero-domestic-capacity finding is sufficient for the criterion (iii) element under the FR 2026-15961 public-comment framework.

U.S. container-terminal throughput at the Port of Los Angeles/Long Beach, Port of New York/New Jersey, Port of Savannah, and Port of Houston is a designated element of the national critical-infrastructure supply chain. Straddle carriers and RTGs directly determine container-handling throughput -- equipment shortages or acquisition delays translate one-for-one into terminal-throughput reduction. Where the specific equipment services a Strategic Seaport under the DoD Strategic Seaport Program, cite the port designation and the DoD-Maritime-Administration memorandum of understanding. Container-terminal-throughput-capacity is discussed in the DHS Cybersecurity and Infrastructure Security Agency's Transportation Systems Sector Critical Infrastructure Plan.

[Domestic suppliers contacted with dates] Written inquiry to any U.S.-based straddle-carrier, RTG, and reach-stacker manufacturer -- expected outcome is documented confirmation that no U.S.-based producer of the specific equipment class exists as of the inquiry date. Cross-reference the American Association of Port Authorities equipment-vendor directory, the National Association of Manufacturers heavy-machinery member list, and the Association of American Railroads intermodal-equipment-supplier list. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments; document the null-response outcome in writing for the inclusion-rebuttal file.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to the downstream customer base: U.S. container-terminal operators (APM Terminals, SSA Marine, Ports America, ITS ConGlobal), intermodal rail operators (BNSF, Union Pacific, Norfolk Southern), and industrial yard operators. Include: (i) 12-month CBP entry records; (ii) documented projection of unit-acquisition delay if the tariff pass-through triggers capex re-scoping; (iii) throughput-per-berth impact projection based on the equipment count deferral.

The global straddle-carrier and RTG production base is concentrated in Finland (Kalmar/Cargotec), Germany (Konecranes-Terex, Liebherr, ZPMC-Terex JV historical), Japan (Mitsubishi Logisnext, Konecranes), and China (ZPMC, Sany). Document contact with alternate-country producers at the specific unit class and quantity. Note that container-terminal-operator specifications frequently pre-qualify a specific OEM shortlist -- substitution across manufacturers requires operator specification-revision cycles.

1. BIS Section 232 Exclusion Portal, historical determinations addressing large-capital-goods derivative articles where domestic manufacturing capacity was documented as zero or near-zero (searchable public docket, regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 39-47 (analysis of downstream capital-goods sectors dependent on imported specialty 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-national-critical-infrastructure basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (i) national-security-nexus and (iii) domestic-capacity. 5. DoD Strategic Seaport Program memorandum of understanding (Maritime Administration and U.S. Transportation Command); DHS CISA Transportation Systems Sector Critical Infrastructure Plan. 6. U.S. Census Bureau NAICS 333923 domestic manufacturing statistics; American Association of Port Authorities (aapa-ports.org) equipment-supplier directory.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of mobile lifting frames on tires and straddle carriers (HTSUS subheading 8426.12) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for straddle-carrier and rubber-tired-gantry equipment used in container-terminal operations at U.S. ports, intermodal rail terminals, and heavy-industrial yards. These are large, capital-intensive units (typical unit weight 60-80 metric tons, unit customs value $500K-$1.5M) built to Occupational Safety and Health Administration container-handling standards and terminal-operator specifications. The domestic manufacturing base for straddle carriers and RTGs is effectively zero -- production is globally concentrated in Finland, Germany, Japan, and China. A 25 percent duty applied here directly increases the acquisition cost of terminal-capacity equipment on which U.S. supply-chain throughput depends. 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.