On May 11, 2020, the US Department of Commerce initiated an investigation into whether laminations for stacked cores for incorporation into transformers (8504.90.963), stacked and wound cores for incorporation into transformers (8504.90.9638; 8504.90.9642), electrical transformers (8504.21 – 8504.23, 8504.32 – 8504.34) and transformer regulators (9032.89.2000; 9032.89.4000) are being imported into the United States in quantities or under circumstances that threaten national security. The numbers in parenthesis are HTS Codes and “transformers” include both liquid and dry transformers with power handling capacities greater than 1 KVA. The investigation under Section 232 of the Trade Expansion Act of 1962, as amended, follows inquiries and requests from multiple members of Congress as well as industry stakeholders.

The Department of Commerce requested public comments on the investigation (please find further details here) on May 19, 2020. The deadline for filing initial comments is June 9, 2020 and the deadline for filing comments in rebuttal is June 19, 2020. Comments in rebuttal may only address issues raised in comments filed on or before June 9, 2020.

“The Department of Commerce will conduct a thorough, fair and transparent review to determine the effects on the national security from imports of laminations for stacked cores for incorporation into transformers, stacked and wound cores for incorporation into transformers, electrical transformers and transformer regulators,” said Secretary Ross.

According to the US Department of Commerce, transformers are part of the US energy infrastructure and an assured domestic supply of transformers and critical transformer components enables the United States to respond to large power disruptions affecting civilian populations, critical infrastructure and US defense industrial production capabilities.

The scope of the investigation includes the following (HTS codes):

1) Laminations for Stacked Cores for Incorporation into Transformers (8504.90.9634)
2) Stacked and Wound Cores for Incorporation into Transformers (8504.90.9638; 8504.90.9642)
3) Electrical Transformers (8504.21 – 8504.23, 8504.32 – 8504.34), i.e., “transformers (liquid and dry), above 1 KVA power handling capacity”
4) Transformer Regulators (9032.89.2000; 9032.89.4000).

Deadline for filing comments: June 9, 2020
Deadline for filing comments in rebuttal: June 19, 2020