Comment letter template for aluminum importers (BIS-14, HTSUS 7603)

If you import aluminum powder classified under HTSUS heading 7603 and want to file a comment on the BIS-14 proposal at Federal Register notice 2026-15961, the TariffWatch template at /tariffwatch/comment-letter/aluminum-powder is a starting point sized for a real filing. This guide walks each section of the template, what the underlying regulation requires it to contain, the mistakes commenters most frequently make, and what changes if you use the file-for-me service instead.

Section 1: Executive summary

The template opens with a plain-language paragraph naming the article (aluminum powder and flake, HTSUS heading 7603), the notice (Federal Register notice 2026-15961 on federalregister.gov), and the requested outcome. This section is your one-paragraph pitch. BIS reviewers read hundreds of comments per docket, and a comment that buries its ask three sections deep loses signal.

The regulation itself does not mandate an executive summary. What it does mandate is that comments respond to the specific statutory criteria the notice identified, and a summary that names those criteria on line one is the fastest way to signal you did.

Section 2: Article-specific impact

The template's second section walks concrete detail on your imports, HTSUS sub-headings, annual volume, supplier country, and downstream product qualification timelines. The reference to AS9100 aerospace certification and multi-year requalification cycles is specific because BIS scores comments on evidentiary weight, and volumetric claims without specifications do not score.

The most common commenter mistake here is HTSUS non-specificity. A comment that says "we import aluminum" without naming a 10-digit sub-heading is treated as an unfocused industry-position statement, not evidence about a specific article. The template's placeholder for {{HTS_CODES}} exists so that you populate real 10-digit sub-headings from your own commercial invoices. Reference for the classification structure is at the CBP rulings and classification resources on cbp.gov, the operational authority Customs uses for classification decisions.

Section 3: Alternative recommendation

The template gives three ranked asks (exclude the heading entirely, phase implementation over 18 months, or establish a product-specific exclusion process). This ranking matters. A comment that only says "please exclude us" without a fall-back position is easier to dismiss than one that gives BIS a concrete phased-implementation option to adopt.

The exclusion process the template references is codified at 15 CFR § 705.5 — the framework BIS historically used to grant product-specific exemptions where domestic supply could not meet a specification. Note: the operative process was terminated by Presidential Proclamations 10895 and 10896 on February 10, 2025 and the BIS exclusions portal is now read-only. The template names § 705.5 by number as historical precedent and asks BIS to *establish* a comparable product-specific carve-out mechanism in the final derivative-article rule. Full regulation text (still codified though non-operative) is at 15 CFR § 705.5 on ecfr.gov.

Section 4: Precedent citations

The template closes with citations to the two source Presidential Proclamations (9704 of 2018 on aluminum, 9705 of 2018 on steel) plus the April 2, 2026 restructuring proclamation, and to BIS's own historical grants for aluminum-powder specifications. A comment that cites the underlying legal framework signals to the reviewer that the commenter understands what BIS can and cannot do.

Common mistake: commenters treat this section as optional. It is not. A comment with zero precedent citations is scored as advocacy rather than as evidence, and advocacy weight is discounted per BIS's own historical published response guidance.

Common commenter mistakes summary

Three failure modes account for most rejected or low-signal comments: HTSUS non-specificity (already discussed), weak economic-impact framing (dollar figures without volume, or claims without contracts), and absent precedent citations. The template pre-scaffolds all three, but the placeholders ({{ANNUAL_VOLUME}}, {{US_EMPLOYEES}}, {{PROJECTED_COST_IMPACT}}) require your real numbers, not the illustrative examples the template ships with.

How the file-for-me service handles this

The $49 file-for-me service at /tariffwatch/comment-letter/file-for-me/aluminum-powder collects your placeholder values through a short form, then a licensed U.S. attorney reviewer merges them into the template, verifies HTSUS specificity, tightens the economic-impact framing to match BIS's published scoring guidance, and files the completed comment into the docket at regulations.gov before the Aug 27 2026 deadline. The service is capped at pre-close filings only, because the docket closes at 11:59 PM Eastern Time on Wednesday Aug 27, 2026 (03:59 UTC on Aug 28).

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FAQ

Do I need a lawyer to file a BIS comment? No. The comment docket is open to anyone. That said, comments that read as unfamiliar with the statutory criteria in the notice score lower than comments that engage the criteria directly.

Is aluminum powder really different from primary aluminum? For Section 232 purposes, yes. Primary aluminum is already covered by the original 2018 action. The Aug 6 2026 BIS-14 proposal contemplates extending coverage to derivative articles like heading 7603 powder and flake, which is why the comment window is open and separate.

What if my Aug 27 filing is late? Late-filed comments are treated as post-docket-close submissions and are docketed for the record but not weighted in BIS's decision-making. The file-for-me service explicitly stops taking new commissions once the Aug 27, 2026 window closes at 11:59 PM Eastern Time (03:59 UTC on Aug 28).

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FAQ

Do I need a lawyer to file a BIS comment?

No. The comment docket is open to anyone. That said, comments that read as unfamiliar with the statutory criteria in the notice score lower than comments that engage the criteria directly.

Is aluminum powder really different from primary aluminum?

For Section 232 purposes, yes. Primary aluminum is already covered by the original 2018 action. The Aug 6 2026 BIS-14 proposal contemplates extending coverage to derivative articles like heading 7603 powder and flake, which is why the comment window is open and separate.

What if my Aug 27 filing is late?

Late-filed comments are treated as post-docket-close submissions and are docketed for the record but not weighted in BIS's decision-making. The file-for-me service explicitly stops taking new commissions once the Aug 27, 2026 window closes at 11:59 PM Eastern Time (03:59 UTC on Aug 28).