Other 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 trailer model: HTSUS 8-10 digit subheading (8716.40 for other trailers/semi-trailers, 8716.39 for residual transport-of-goods trailers), trailer class (enclosed cargo, open utility, equipment hauler, dump trailer, low-boy, tag-along, gooseneck), gross vehicle weight rating (GVWR), axle count and axle rating, deck length and width, hitch class (Class II/III/IV/V for tag-along, gooseneck, or fifth-wheel), NATM (National Association of Trailer Manufacturers) compliance-verification-program status, and unit customs value. Include the DOT vehicle-identification-plate rubbing, the NATM CVP verification certificate where applicable, and the Federal Motor Vehicle Safety Standard (FMVSS 108/121) compliance documentation.

Document each U.S.-based trailer manufacturer at the specific trailer class. The domestic base is large but fragmented: enclosed cargo and utility trailers are produced by Wells Cargo, ATC Trailers, Continental Cargo, Diamond C Trailer, PJ Trailers, Big Tex Trailers, Load Trail, Lamar Trailers, and many regional fabricators. Equipment-hauler and low-boy classes are produced by XL Specialized Trailers, Talbert Manufacturing, Trail King Industries, and Landoll Corporation. Contact each producer at the specific class and specification. Reference U.S. Census Bureau NAICS 336212 (Truck Trailer Manufacturing) domestic-production statistics and the National Association of Trailer Manufacturers (natm.com) member directory to confirm the domestic-supplier universe is fully canvassed at the specific trailer class.

Utility, cargo, and equipment-transport trailers are broadly deployed in commercial construction, landscaping, contractor tool-transport, and consumer applications. The direct national-security nexus is limited for most categories; heavy-equipment low-boy and drop-deck classes support DoD-installation buildout, defense-contractor equipment movement, and Federal Emergency Management Agency (FEMA) mobile-command staging. Where the specific units serve federal-agency contracts (GSA, DoD, FEMA), cite the specific contract or program. 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: specific specification-class shortages within a large aggregate category still constitute domestic-capacity gaps under BIS methodology.

[Domestic suppliers contacted with dates] Written inquiry to each U.S.-based trailer manufacturer identified through the National Association of Trailer Manufacturers directory (natm.com) at the specific trailer class, GVWR, deck configuration, and delivery timeline. For NATM CVP-verified categories, verify the alternate producer holds current CVP verification -- FMVSS-compliance-required categories cannot be substituted with a non-compliant producer. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments; Big Tex, Load Trail, and PJ Trailers dominate specific mass-market enclosed and utility classes and their specification-match claims should be pre-addressed at the model level.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to downstream customers: independent trailer dealers, tractor-and-implement dealers, contractor-equipment rental fleets, and direct-to-consumer channels. Include: (i) 12-month CBP entry records; (ii) downstream customer segment analysis (percent to commercial contractor, percent to consumer, percent to rental-fleet); (iii) documented projection of unit-sales elasticity based on prior tariff-round pass-through observed in the 2018-2019 Section 232 rounds for related HTSUS 8716 categories.

The global other-trailer production base is regionally distributed with significant capacity in Canada (Trailtech, Big Tex Canada, Rainbow Trailers), Mexico (Loanper Trailers, Coprovisa), Germany (Humbaur, Böckmann), and China (multiple export-oriented fabricators). Document contact with alternate-country producers at the specific trailer class. Note that NATM CVP verification, FMVSS-compliance requirements, and DOT VIN-assignment authority are non-waivable U.S. requirements -- alternate producers must already hold the required U.S. compliance credentials for the specific trailer class.

1. BIS Section 232 Exclusion Portal, historical determinations addressing HTSUS 8716 trailer derivative articles at specific specification classes where domestic capacity 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 steel-fabrication sector analysis). 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-downstream-fabrication basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (iii) domestic-capacity and (iv) downstream-employment. 5. Federal Motor Vehicle Safety Standard (FMVSS) 108 (Lamps, Reflective Devices, and Associated Equipment) and FMVSS 121 (Air Brake Systems); National Association of Trailer Manufacturers Compliance Verification Program. 6. U.S. Census Bureau NAICS 336212 (Truck Trailer Manufacturing) domestic manufacturing statistics; National Association of Trailer Manufacturers (natm.com) annual industry statistics.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of other trailers and semi-trailers not elsewhere specified (HTSUS subheading 8716.40 and residual 8716.39 categories) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for specialty utility, cargo, and equipment-transport trailers built on steel-frame chassis for commercial and consumer use. Categories include enclosed cargo trailers, open utility trailers, equipment/car-hauler trailers, dump trailers, and low-boy/heavy-equipment trailers where the specific specification is not currently produced at commercial volume domestically or the domestic supply cannot meet the annual demand at the referenced price point. The primary-metal share of finished-good value ranges 45-65 percent (steel-frame chassis, torsion or leaf-spring suspension, decking). 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.