Welding-machine 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 part: OEM part number, OEM manufacturer name, HTSUS 8-10 digit subheading, physical specifications (dimensions, materials, weight, function within the parent welding-machine assembly), the specific parent equipment model(s) the part services, and a copy of the OEM parts catalog page listing the part number. Where a single inclusion rebuttal comment covers multiple related part numbers under one HTSUS subheading, list every included part number in a schedule attached to the request -- do not aggregate without enumeration.

OEM-parts rebuttal analysis differs from a raw-material rebuttal analysis: the relevant capacity question is not 'can any U.S. producer manufacture a MIG-gun consumable' but 'can any U.S. producer manufacture THIS OEM-specific consumable to the OEM's published dimensional and material specification, at the OEM's own quality standard'. Contact each domestic welding-equipment manufacturer capable of producing an equivalent OEM-specification part (Lincoln Electric, Miller Electric division of ITW, ESAB, Hobart, Thermal Arc), document each response, and cite the OEM's own published statement (if any) on whether the specific part is manufactured domestically or sourced through the OEM's international supply chain. Reference U.S. Census Bureau NAICS 333992 (welding and soldering equipment manufacturing) domestic production data.

Welding-equipment uptime supports the domestic fabrication sector the underlying Section 232 steel action was intended to strengthen. If the specific parts requested for exclusion service defense-related fabrication (DoD prime contracts, shipbuilding under the Merchant Marine Act, defense-adjacent Tier 1 supplier facilities), cite specific programs. If not, state the commercial-fabrication end use directly -- the rebuttal analysis still proceeds under criterion (v) 'other information the commenter believes relevant' of Federal Register notice 2026-15961's public-comment invitation on the basis that a 25% duty on OEM-specific parts operates AGAINST the Section 232 policy's stated purpose by reducing domestic-fabrication equipment availability.

[Domestic suppliers contacted with dates] Complete a documented check with every U.S.-based welding-equipment OEM listed above, including specifically requesting whether the OEM produces the exact part number in the United States. OEMs frequently source aftermarket parts through their own international supply chains even when the finished machine is assembled in the U.S. -- get this in writing. Objectors (typically OEMs asserting they DO produce the specific part domestically) have 30 days from public-docket posting to file a competing statement; the inclusion rebuttal comment should be structured to preempt the most likely objection by naming the objecting party and pre-addressing the specification-match question.

Quantify the pass-through cost of a 25% duty on [Annual customs value USD] of imports at HTSUS [HTSUS 8-10 digit subheading] to the downstream small- and mid-size fabrication shops, ironworkers, and skilled-trades apprenticeship programs that consume these parts. Include: (i) 12-month import records; (ii) downstream customer segment analysis showing what percentage of parts volume ships to shops with fewer than 50 employees; (iii) projected welding-equipment downtime multiplier if the cost increase reduces parts stocking by downstream distributors.

For each part number, identify whether the OEM sources from any producer in a country not subject to the proposed Section 232 rate. In most OEM aftermarket-parts categories the answer is no -- OEMs concentrate their aftermarket manufacturing in one or two source countries. Where an alternate-country source exists, document landed-cost comparison and lead-time impact.

1. BIS Section 232 Exclusion Portal, historical determinations addressing OEM-specific replacement parts across multiple derivative-article categories where domestic supply cannot meet OEM-qualified specifications (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 fabrication employment and the equipment-uptime multiplier). 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 (national-security-adjacent domestic-fabrication basis). 4. Federal Register notice 2026-15961 (August 6, 2026), criteria (iii) domestic-capacity and (iv) downstream-employment. 5. U.S. Census Bureau NAICS 333992 (Welding and Soldering Equipment Manufacturing) annual domestic-production statistics. 6. Trade Expansion Act of 1962, Section 232, 19 U.S.C. § 1862.

This public comment is submitted in opposition to the proposed Section 232 derivative-article inclusion of parts of welding machines and apparatus (HTSUS heading 8515) contemplated by Federal Register notice 2026-15961. [Company legal name] requests a product-specific exclusion for OEM-specific welding-machine replacement parts (MIG-gun consumables, TIG torch bodies, wire-feed motor assemblies, transformer components) that are sold under an OEM part number for welding equipment already in service in the United States. There is no meaningful domestic substitution: a Miller MIG gun requires Miller-manufactured replacement necks, a Lincoln machine requires Lincoln parts, and the OEMs' own U.S. distribution networks source those parts through the same overseas supply chains our imports track. The proposed 25% duty would raise the cost of maintaining welding equipment in domestic use -- an outcome directly at odds with the Section 232 policy's own purpose of supporting domestic fabrication. 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 12-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.