Other self-propelled cranes and mobile lifting frames -- 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 (8426.41 for other self-propelled cranes on wheels), unit type (rough-terrain, all-terrain, truck-crane, or crawler-mounted), rated safe-working-load in metric tons at the referenced radius, maximum boom length (main boom and jib), OEM manufacturer (Liebherr, Grove/Manitowoc, Tadano, Terex-Demag, Kobelco, Link-Belt, Sany, XCMG), unit customs value, and identified end-use application. Include OEM technical data sheet, ANSI B30.5 compliance documentation, and the Society of Automotive Engineers (SAE) J1063 stability documentation. Note aluminum boom-section content and structural steel content by weight where the OEM discloses.

Document each U.S.-based self-propelled-crane manufacturer at the referenced capacity class. The domestic manufacturing base above 100 metric tons includes Grove (Manitowoc), Link-Belt Construction Equipment (Sumitomo), and Terex historical production -- capacity in specific rough-terrain and all-terrain classes is limited and often exceeded by market demand during construction-cycle peaks. Contact each U.S. producer at the specific capacity, boom-length, and configuration requested. Reference U.S. Census Bureau NAICS 333120 (Construction Machinery Manufacturing) domestic-production statistics and the Specialized Carriers & Rigging Association (SC&RA) member directory and the Association of Equipment Manufacturers (AEM) crane-and-lifting-equipment section.

Mobile cranes at the referenced capacity class support critical infrastructure buildout (utility transmission tower installation, wind-turbine erection, bridge and highway construction, refinery turnaround and petrochemical plant maintenance) that is central to the Bipartisan Infrastructure Law, CHIPS Act facility buildout, and Inflation Reduction Act energy-project buildout. Where specific units service defense-related construction (DoD-installation buildout, Naval-shipyard maintenance, defense-critical utility infrastructure), cite the 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: equipment-availability shortages at this capacity class directly delay federally-funded infrastructure projects and defense-adjacent capex.

[Domestic suppliers contacted with dates] Written inquiry to each U.S.-based self-propelled-crane manufacturer above (Grove/Manitowoc, Link-Belt, remaining Terex operations) at the specific rated capacity, boom length, and configuration -- generic 'mobile crane' is not a sufficient inquiry. For lattice-boom crawler cranes above 500 metric tons, the domestic manufacturing base narrows to Manitowoc's Wisconsin facility. Cross-reference the Specialized Carriers & Rigging Association member directory, the Association of Equipment Manufacturers directory, and the SC&RA Crane Program-certification listings. 30-day minimum response window. Objectors have 30 days from posting of this rebuttal comment on regulations.gov to file counter-comments.

Quantify the 25 percent duty pass-through on [Annual customs value USD] at HTSUS [HTSUS 8-10 digit subheading] to downstream customers: crane rental fleets (Maxim Crane Works, ALL Crane, Bigge Crane, Buckner HeavyLift), general contractors, and infrastructure specialists. Include: (i) 12-month CBP entry records; (ii) documented projection of crane-fleet acquisition deferral if the tariff pass-through triggers rental-house capex re-scoping; (iii) downstream project-cost pass-through into federally-funded infrastructure projects (bridge replacement, transmission upgrade, wind-farm construction).

The global self-propelled-crane production base at 100+ metric ton capacity is concentrated in Germany (Liebherr, Terex-Demag), Japan (Tadano, Kobelco), Italy (Locatelli), and China (Sany, XCMG, Zoomlion). Document contact with alternate-country producers at the specific capacity class. Note that crane-rental fleets frequently standardize on a specific OEM to control parts inventory and operator training -- OEM substitution has a real fleet-integration cost.

1. BIS Section 232 Exclusion Portal, historical determinations addressing large mobile-crane categories where U.S. capacity at the specific rating class was documented as insufficient (searchable public docket, regulations.gov (Docket BIS-2026-15961)). 2. Commerce Department Section 232 steel report, January 11, 2018, at 39-47 (downstream capital-goods 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-federally-funded-infrastructure basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (iii) domestic-capacity and (iv) downstream-employment. 5. ANSI/ASME B30.5 (Mobile and Locomotive Cranes) safety standard; SAE J1063 (Cantilevered Boom Crane Structures - Method of Test) engineering standard. 6. U.S. Census Bureau NAICS 333120 (Construction Machinery Manufacturing) domestic manufacturing statistics; Association of Equipment Manufacturers (AEM) annual industry statistics.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of other self-propelled cranes and mobile lifting frames (HTSUS subheading 8426.41) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for rough-terrain, all-terrain, and truck-mounted mobile cranes above 100 metric tons rated capacity, including telescoping-boom and lattice-boom configurations. These units support U.S. construction, utility, wind-power installation, refinery-turnaround, and petrochemical-maintenance work at capacities where the domestic manufacturing base is limited. Boom-section extrusions and structural steel plate incorporated in these units carry the underlying Section 232 primary-metal nexus, but the finished-good value is dominated by hydraulic systems, drivetrain, controls, and OEM-specific engineered lifting hardware. 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.