The U.S. International Trade Commission (Commission or USITC) today released a U.S. Trade Representative (USTR)-requested report that calculates the greenhouse gas (GHG) emissions intensities of U.S. steel and aluminum industries. The report, Greenhouse Gas Emissions Intensities of the U.S. Steel and Aluminum Industries at the Product Level, was requested by the USTR in a letter received on June 5, 2023. 

USTR’s request letter asked the USITC to:

• Calculate the GHG emissions intensity of steel and aluminum produced in the United States by product category in 2022, with data on scope 1, 2 and 3 emissions. 
• Describe the methodologies the USITC used to collect relevant information and calculate the emissions intensity estimates.
• Identify where emissions occur during manufacturing, with respect to the production stages and sourcing location of inputs. 

To gather data for the calculation of product-level emissions intensity estimates, the USITC surveyed all U.S. facilities that produced the steel and aluminum products covered under the section 232 investigation in 2022.

This report conveys the Commission’s factual findings and analyses. The Commission makes no recommendations on policy or other matters in this report. 

Major Findings of the Investigation

The processes and inputs used in U.S. steel and aluminum production drive their emission intensities.

Semifinished Steel

The average emissions intensity estimate for U.S. carbon and other alloy semifinished steel was 1.02 metric tons of carbon dioxide equivalent per metric ton of steel (mt CO2e/mt steel) in 2022.

• The emissions intensities estimates of U.S. carbon and alloy steel products are primarily influenced by two factors: 
  • The production pathway (the more emissions-intensive blast furnace and basic oxygen furnace, or BF-BOF, pathway, versus the electric arc furnace, or EAF, pathway) used to produce the semifinished steel, which is used as substrate in mill products.
  • The relative use of emissions-intensive upstream material inputs like pig iron and direct reduced iron.
• The average emissions intensity for U.S. stainless steel semifinished steel was 2.23 mt CO2e/mt steel in 2022. The emissions intensity of U.S. stainless steel products is mainly influenced by the reliance on emissions-intensive ferroalloy (an alloy of iron with a significant amount of one or more other elements, like chromium or nickel) inputs. All U.S. stainless semifinished steel-producing facilities reported operating an EAF. Therefore, variation in the production pathway does not drive emissions intensities for stainless steel.

Steel Mill Products

Average emissions intensities among carbon and alloy steel mill products ranged between 0.67 mt CO2e/mt steel for hot-worked long products and 2.17 mt CO2e/mt steel for coated flat products. Average emissions intensities among stainless steel mill products ranged between 2.31 mt CO2e/mt steel for hot-rolled flat and 4.55 mt CO2e/mt steel for wire.

• Further downstream steel products generally had higher emissions intensities than less-processed steel products. This is because each subsequent process in steel production involves more steps and therefore more opportunities for emissions.
• For carbon and alloy steel mill products, the most emissions-intensive processes in the U.S. steel industry occur during the upstream production of pig iron and semifinished steel. The additional subprocesses used to produce downstream products are also significant, however, leading to meaningful differences in emissions intensities across the carbon and alloy steel product categories.
• Stainless steel mill products are more emissions intensive than their carbon and alloy steel counterparts. This is due to the heavier use of energy and ferroalloys associated with stainless steel production.

Unwrought Aluminum

The average emissions intensity for all U.S. unwrought aluminum is 3.46 mt CO2e/mt aluminum. U.S. unwrought aluminum includes primary aluminum, which is produced from alumina at smelters using electrolysis, and secondary aluminum, which is produced by remelting primary aluminum and scrap-based inputs. Most U.S. unwrought production, in terms of volume and number of facilities, is of secondary unwrought aluminum.

• The average emissions intensity for U.S. primary unwrought aluminum is 14.52 mt CO2e/mt aluminum. The main drivers of the emissions intensity of primary unwrought aluminum are:
  • The large quantities of electricity needed for electrolysis. 
  • The fuel mix used to generate high quantities of the necessary electricity.
• The average emissions intensity for U.S. secondary unwrought aluminum is 2.46 mt CO2e/mt aluminum. Production of secondary unwrought aluminum is much less energy intensive, using a fraction of the electricity of primary unwrought production. The emissions intensity of secondary unwrought aluminum is influenced by the amount of primary unwrought aluminum versus scrap used as inputs and, to a lesser extent, by the efficiency of the furnaces used to heat the metal.

Wrought Aluminum

The average emissions intensities for U.S. wrought aluminum products ranged from 4.97 mt CO2e/mt aluminum for plates, sheets and strip, to 8.66 mt CO2e/mt aluminum for foil. The two main factors that drive the differences in emissions intensities between wrought product categories are the:

• Amount of primary versus secondary unwrought aluminum used. 
• Energy intensity of the various manufacturing processes.

Note: The Commission’s emissions intensity estimates for both steel and aluminum are calculated assuming that scrap inputs have zero embedded emissions.

Greenhouse Gas Emissions Intensities of the U.S. Steel and Aluminum Industries at the Product Level (Investigation No. 332-598, USITC Publication 5584, February 2025) is available on the USITC website.

About Factfinding Investigations

USITC general factfinding investigations culminating in a report, such as this one, cover matters related to tariffs, trade and competitiveness and are generally conducted under section 332(g) of the Tariff Act of 1930 at the request of the U.S. Trade Representative, the House Committee on Ways and Means or the Senate Committee on Finance. The resulting reports convey the Commission’s objective findings and independent analyses on the subjects investigated. The Commission makes no recommendations on policy or other matters in its general factfinding reports. Upon completion of each investigation, the USITC submits its findings and analyses to the requester. General factfinding investigation reports are subsequently released to the public unless they are classified by the requester for national security reasons.

The U.S. International Trade Commission (USITC) is undertaking a new factfinding investigation that will examine the impact of tariffs on U.S. imports under section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862) and section 301 of the Trade Act of 1974 (19 U.S.C. 2232) in effect as of March 15, 2022, as reflected in the Harmonized Tariff Schedule. The Commission’s report will provide detailed information on U.S. trade, production, and prices in the industries directly and most affected by these tariffs.

The Commission was directed to conduct this investigation, Economic Impact of Section 232 and 301 Tariffs on U.S. Industries, Inv. 332-591, as part of the Omnibus Appropriations Act, which was signed into law on March 15, 2022.

As directed, the USITC, an independent, nonpartisan, federal agency, will prepare a public report. The report will provide, to the extent practicable:

• background information on the Section 232 and 301 tariffs and an overview of the tariffs that were in effect as of March 15, 2022; and
• an economic analysis of the impact of these tariffs on U.S. trade, production, and prices in the industries most affected by these tariffs.

The USITC expects to submit its report to Congress by March 15, 2023.

The USITC will hold a public hearing in connection with the investigation, beginning at 9:30 a.m. on July 21, 2022. Information about the hearing, including how to participate or observe, will be posted on the Commission’s website no later than June 21, 2022, at https://usitc.gov/research_and_analysis/what_we_are_working_on.htm. 

Requests to appear at the hearing should be filed no later than 5:15 p.m. on July 6, 2022 with the Secretary, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436.  See below for important information regarding filing a request to appear at a USITC hearing.

The USITC also welcomes written submissions for the record.  Written submissions should be addressed to the Secretary of the Commission and should be submitted no later than 5:15 p.m. on August 24, 2022. All written submissions, except for confidential business information, will be available for public inspection.  See below for important information regarding the filing of written submissions for USITC investigations.

IMPORTANT:  All filings to appear at the hearing and written submissions must be made through the Commission’s Electronic Document Information System (EDIS, https://edis.usitc.gov). No in-person paper-based filings or paper copies of any electronic filings will be accepted until further notice. Persons with questions regarding electronic filing should contact the Office of the Secretary, Docket Services Division (EDIS3Help@USITC.gov), or consult the Commission’s Handbook on Filing Procedures.

Further information on the scope of the investigation is available in the USITC’s notice of investigation, dated May 5, 2022, which can be downloaded from the USITC Internet site (www.usitc.gov)  or may be obtained by contacting the Office of the Secretary at or may be obtained by contacting the Office of the Secretary at commissionhearings@usitc.gov.

The U.S. International Trade Commission (USITC) has released the first of two reports on foreign censorship policies and practices that affect U.S. businesses. 

The investigations, Foreign Censorship Part 1: Policies and Practices Affecting U.S. Businesses and Foreign Censorship Part 2: Trade and Economic Effects on U.S. Businesses, were requested by the Senate Committee on Finance in a letter received on April 8, 2021, modifying its earlier letter of January 4, 2021.

As requested, in the first report, the USITC, an independent, nonpartisan federal agency, identified and described various foreign censorship practices, with particular focus on examples that U.S. businesses cite as impeding trade or investment in key foreign markets.

The report includes:

• a description of the evolution of censorship and censorship-enabling policies and practices over the past five years in six key foreign markets: China, Russia, Turkey, Vietnam, India, and Indonesia; and
• a description of elements that entail extraterritorial censorship and the roles of governmental and nongovernmental actors in implementing and enforcing censorship policies and practices in these six key foreign markets.

Detailed information on the Commission's findings can be found in the report's Executive Summary.

Foreign Censorship, Part 1: Policies and Practices Affecting U.S. Businesses (Investigation No. 332-585, USITC publication 5244, December 2021) is available on the USITC's internet site at https://www.usitc.gov/publications/332/pub5244.pdf.

About these investigations: USITC general factfinding investigations, such as these, cover matters related to tariffs or trade and are generally conducted under section 332(g) of the Tariff Act of 1930 at the request of the U.S. Trade Representative, the House Committee on Ways and Means, or the Senate Committee on Finance. The resulting reports convey the Commission’s objective findings and independent analyses on the subjects investigated. The Commission makes no recommendations on policy or other matters in its general factfinding reports. Upon completion of each investigation, the USITC submits its findings and analyses to the requester. General factfinding investigation reports are subsequently released to the public unless they are classified by the requester for national security reasons.

The U.S. International Trade Commission (USITC) is undertaking a new factfinding investigation on operations and conditions of competitiveness in U.S. foreign trade zones and similar programs in Canada and Mexico (FTZs).

The investigation, Foreign Trade Zones (FTZs): Effects of FTZ Policies and Practices on U.S. Firms Operating in U.S. FTZs and Under Similar Programs in Canada and Mexico, Inv. No. 332-588, was requested by the U.S. Trade Representative (USTR) in a letter received on December 14, 2021.

As requested, the USITC, an independent, nonpartisan, factfinding federal agency, will prepare a public report for the USTR. The report will provide, to the extent practicable:

• an overview of economic activity in FTZs operating in the United States, Canada, and Mexico since 2016;
• an overview of the current FTZ policies and practices in the United States, Canada, and Mexico; and
• an analysis of the effects of current FTZ policies and practices in the United States, Canada, and Mexico on the cost-competitiveness of products of U.S. firms operating in these FTZs.

The USITC expects to submit its report to the USTR by April 14, 2023.

The USITC will hold a public hearing in connection with the investigation at 9:30 a.m. on May 17, 2022.  Information about how to participate in the hearing, including whether it will be virtual, will be posted on the Commission’s website no later than April 12, 2022, at https://usitc.gov/research_and_analysis/what_we_are_working_on.htm.  

Requests to appear at the hearing should be filed no later than 5:15 p.m. on May 3, 2022 with the Secretary, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436.  See below for important information regarding filing a request to appear at a USITC hearing.

The USITC also welcomes written submissions for the record.  Written submissions should be addressed to the Secretary of the Commission and should be submitted no later than 5:15 p.m. on November 30, 2022. All written submissions, except for confidential business information, will be available for public inspection.  See below for important information regarding the filing of written submissions for USITC investigations.

IMPORTANT:  All filings to appear at the hearing and written submissions must be made through the Commission’s Electronic Document Information System (EDIS, https://edis.usitc.gov). No in-person paper-based filings or paper copies of any electronic filings will be accepted until further notice. Persons with questions regarding electronic filing should contact the Office of the Secretary, Docket Services Division (EDIS3Help@USITC.gov), or consult the Commission’s Handbook on Filing Procedures.

Further information on the scope of the investigation is available in the USITC’s notice of investigation, dated January 26, 2021, which can be downloaded from the USITC Internet site (www.usitc.gov) or may be obtained by contacting the Office of the Secretary at or may be obtained by contacting the Office of the Secretary at commissionhearings@usitc.gov. .

About these investigations: USITC general factfinding investigations, such as these, cover matters related to tariffs or trade and are generally conducted under section 332(g) of the Tariff Act of 1930 at the request of the U.S. Trade Representative, the House Committee on Ways and Means, or the Senate Committee on Finance. The resulting reports convey the Commission’s objective findings and independent analyses on the subjects investigated. The Commission makes no recommendations on policy or other matters in its general factfinding reports. Upon completion of each investigation, the USITC submits its findings and analyses to the requester. General factfinding investigation reports are subsequently released to the public unless they are classified by the requester for national security reasons.

The U.S. International Trade Commission (USITC) today released a report on U.S. industries producing COVID-19 related goods and the supply chain challenges and constraints that impacted the availability of such goods.

The investigation, COVID-19 Related Goods: The U.S. Industry, Market, Trade, and Supply Chain Challenges, was requested by the U.S. House of Representatives’ Committee on Ways and Means and the U.S. Senate Committee on Finance in a letter received on August 13, 2020.

As requested, the USITC, an independent nonpartisan factfinding federal agency, completed the investigation as a follow-on to an earlier report that identified goods related to treating and otherwise responding to the COVID-19 pandemic.  Released in May 2020 and updated in June 2020, that report identified the goods’ source countries, tariff classifications, and applicable duty rates. 

The new report, focused primarily on the availability of goods from the onset of the COVID-19 pandemic through September 2020, provides overviews of four key industry sectors (medical devices, personal protective equipment, pharmaceuticals, and soaps and cleaning compounds). In addition, the report includes case studies on ventilators, N95 respirators, surgical masks, surgical and isolation gowns, medical and surgical gloves, test kits, vaccines, and hand sanitizer.

Major Findings:

• U.S. demand for all products covered in the case studies substantially increased in the first half of 2020, as compared to 2019, leading to significant shortages. Domestic industries were able to continue current operations but faced challenges in ramping up production to meet growing demand. Importers of COVID-19 related goods faced disruptions to normal levels of supply for some products and challenges associated with a rapid increase in global demand.


• The United States produced all goods covered in the case studies before the pandemic, as well as many of the inputs. However, the extent of domestic production varied significantly. The U.S. industry supplied only a relatively small share of the domestic market for certain medical PPE, such as medical gloves and gowns, but supplied a large share of the domestic market for goods like ventilators, vaccines, N95 respirators, and hand sanitizer.


• U.S. imports of most COVID-19 related goods covered in the case studies increased substantially beginning around April or May 2020, depending on the product. Imports of many products exceeded their normal levels by orders of magnitude. Medical and surgical gloves, however, remain among the most hard-to-find items, with glove imports up only 17 percent during January-September 2020.


• Some of the initial supply chain challenges have eased, such as those for ventilators, but a number remain, including for many PPE items.  Gloves, for example, are one of the most highly constrained COVID-19 related products, with shortages expected to continue beyond 2021.


• The major factors affecting domestic production of COVID-19 related goods include the availability and costs of inputs, the time and cost of bringing additional production capacity online (including purchasing and installing new machinery), and the time needed to recruit and train new workers. For firms entering the market or bringing new products to the market, challenges also include the time associated with designing products and getting them certified, as well as issues related to a hesitancy among purchasers to use unknown suppliers. Finally, U.S. producers faced, and continue to face, a conundrum when deciding whether to invest in domestic production, as there is little certainty about long-term demand and the ability to recoup investments, and a concern that post-pandemic purchasers will revert to buying from the lowest-cost suppliers, which often manufacture overseas.


• The most significant factor affecting imports was that global demand significantly exceeded available supply of many COVID-19 related goods, making it difficult for U.S. importers to procure sufficient quantities. Other major factors included substantially higher prices for imports, foreign export restrictions, logistics disruptions and cost increases, quality concerns (a significant increase in the number of counterfeit, illicit, and flawed products), and imported products differing from those used in the U.S. market.

COVID-19 Related Goods: The U.S. Industry, Market, Trade, and Supply Chain Challenges (Investigation No. 332-580, USITC Publication 5145, December 2020) is available on the USITC website at: https://www.usitc.gov/publications/332/pub5145.pdf.

USITC general factfinding investigations cover matters related to tariffs or trade and are generally conducted at the request of the U.S. Trade Representative, the House Committee on Ways and Means, or the Senate Committee on Finance. The resulting reports convey the Commission's objective findings and independent analyses on the subjects investigated. The Commission makes no recommendations on policy or other matters in its general factfinding reports. Upon completion of each investigation, the USITC submits its findings and analyses to the requester. General factfinding investigation reports are subsequently released to the public, unless they are classified by the requester for national security reasons.

Ten years after its implementation, the Earned Import Allowance Program (EIAP) did not provide enough incentives to significantly boost Dominican apparel exports to the U.S. market, reports the U.S. International Trade Commission (USITC) in its publication Earned Import Allowance Program: Evaluation of the Effectiveness of the Program for Certain Apparel from the Dominican Republic; Tenth Annual Review.

The program terminated by statute on December 1, 2018.

The EIAP allowed apparel manufacturers in the Dominican Republic who used U.S. fabric to produce certain apparel to earn a credit that could be used to ship eligible apparel made with non-U.S.-produced fabric into the United States duty free. The Dominican Republic-Central America-United States Free Trade Agreement Implementation Act, as amended, required the USITC, an independent, nonpartisan, factfinding federal agency, to evaluate annually the effectiveness of the EIAP program and make recommendations for improvements.

The USITC's 10th and final annual review was submitted to the U.S. House of Representatives Committee on Ways and Means and the U.S. Senate Committee on Finance on September 17, 2019. Highlights of the report follow.

• Of the 13 registered firms, only four used the program in its final year, the same as the prior year.
• In 2018, U.S. imports of woven cotton bottoms from the Dominican Republic fell 4 percent by value to just under $1.4 million in 2018, down from $1.5 million in 2017, and fell 2 percent by quantity to 150,716 SMEs in 2018 from 153,679 SMEs in 2017. The continued decline in U.S. imports under the EIAP in its final year likely reflects a significant decline in woven trouser manufacturing capacity in the Dominican Republic, a simultaneous shift by U.S. importers to Asian suppliers during the life of the program, and anticipation of the expiration of the program on December 1, 2018. The general decline in the program’s usage after U.S. imports under the EIAP peaked in 2010 may also reflect the lack of changes made to the program despite the recommendations put forth since the first annual review.
• No new recommendations to improve the program were received during the 10th annual review of the EIAP, nor were there any known requests or efforts to extend the program beyond its expiration date. During the previous nine annual reviews, the government of the Dominican Republic, industry representatives, and users of the program consistently made three principal recommendations to improve the EIAP: 1) lower the 2-for-1 ratio of U.S. to foreign fabric to a 1-for-1 ratio; 2) expand the program coverage to enable other types of fabrics and apparel items to be included in the EIAP; and 3) change the requirement that dyeing and finishing of eligible fabrics occur in the United States.

Earned Import Allowance Program: Evaluation of the Effectiveness of the Program for Certain Apparel from the Dominican Republic; Tenth Annual Review (Inv. No. 332-503, USITC Publication 4950, September 2019) is available on the USITC's Internet site at http://www.usitc.gov/publications/332/pub4950.pdf

USITC general factfinding investigations, such as this, cover matters related to tariffs or trade and are generally conducted at the request of the U.S. Trade Representative, the House Committee on Ways and Means, and the Senate Committee on Finance. The resulting reports convey the Commission's objective findings and independent analyses on the subject investigated. The Commission makes no recommendations on policy or other matters in its general factfinding reports. Upon completion of each investigation, the USITC submits its findings and analyses to the requester. General factfinding investigations reports are subsequently released to the public, unless they are classified by the requester for national security reasons.

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