Earlier this week, our firm sponsored a panel discussion entitled “Export Compliance for Aerospace & Defense Firms – What the OEMs Expect from Their Supply Chain” as part of Connecticut Export Week 2018.  Joanne Rapuano, Counsel in Robinson & Cole’s Trade Compliance practice, moderated the discussion.  The panel included Matthew Borman, Deputy Assistant Secretary of Commerce for Export Administration and trade compliance officers from major aerospace and defense manufacturers.

Mr. Borman discussed something on the minds of many manufacturers, i.e., the new steel and aluminum tariffs.  He mentioned that the Department of Commerce has published information regarding those seeking exclusions from the new tariffs.  As mentioned by the Department of Commerce, in determining whether to grant an exclusion, “the Secretary will consider whether a product is produced in the United States of a satisfactory quality or in a sufficient and reasonably available amount.”  Significantly, any requests for exclusions will be published for the public to see and U.S. parties can file objections.  We have already started to receive calls about applying for exclusions.  Yet, even if your company does not apply for one, you should monitor the public filings to see whether your competitors are doing so.