In response to the U.S. Department of Commerce's "Notice for Public Comments on Section 232 National Security Investigation of Imports of Steel," ISRI filed comments highlighting
the strong interconnections between the U.S. scrap recycling and primary steel industries. In the submission, we remarked that a healthy steel industry means a healthy circular economy, an unfettered supply chain, job creation, and overall stable economic activity for both the U.S. steel industry and for the U.S. scrap recycling industry. ISRI also drew attention to the environmental benefits of using scrap, especially the 65 percent energy saved, greenhouse gas emissions eliminated, and preventing valuable materials from ending up in landfills. Economically, the industry generates $180 billion of economic activity in the United States and supports more than 530,000 direct and indirect jobs.
The investigation is the result of one of several executive orders signed by President Trump to conduct comprehensive reviews of existing and pending regulations as well as investigating unfair trade practices that harm U.S. industries and American workers. ISRI made it very clear that the U.S. steel industry is not only the U.S. scrap recycling industry's largest customer for scrap, but also generates significant volumes of ferrous scrap through its manufacturing process. Stable and highly functioning markets for U.S. ferrous scrap should result in an unbreakable supply chain of specification grade commodities that flow seamlessly back into the steel supply stream, and thus, new American-made steel is readily available.
Furthermore, ISRI emphasized the industry's strong support for free and fair trade and applauded the recent enforcement actions against unfair trading practices. More than 80 percent of domestically- produced ferrous scrap is consumed by the U.S. steel industry, while the remaining volume is exported to many nations helping to reduce our nation's trade imbalance. However, while not a subject of this investigation, ISRI cautioned the Administration about the dangers from restrictions to trade citing the experiences of the 1970s when steel scrap export restrictions resulted in price spikes and shortages as a result of the constrained global supply of ferrous scrap. The global ferrous scrap market is one of the purest examples of supply and demand economics and as a globally-traded commodity, scrap is less dependent on local supplies or local markets.