OFII Submits Comments on Commerce’s Auto Investigation

June 29, 2018

WASHINGTON – The Organization for International Investment (OFII) today submitted comments to the U.S. Department of Commerce regarding its Section 232 automotive imports investigation. Excerpts of the letter are below: 

“The Department’s Section 232 investigation into whether, ‘imports of automobiles, including SUVs, vans and light trucks, and automotive parts into the United States threaten to impair [U.S.] national security,’ is misguided and unnecessary.

“In launching the investigation, Secretary Ross wrote to Secretary of Defense James Mattis: ‘There is evidence suggesting that, for decades, imports from abroad have eroded our domestic auto industry.’ Yet, when asked by Senator Orrin Hatch during a Senate Finance Committee hearing on June 20, to provide the requisite evidence upon which the Department initiated its investigation, Secretary Ross stated: ‘Well, as you know, the investigation, Mr. Chairman, has just begun so we do not have the detailed answers to any of those questions.’

“Here are some facts that are evident:

“The Bureau of Economic Analysis (BEA) reports that job creation by international auto manufacturers in the United States has increased by 79 percent in the past five years, compared to a 35 percent increase from the overall U.S. auto industry…. U.S. exports by international companies in the automotive sector have also grown by a staggering 200 percent [over that same period].”


“It is also worth noting that global automakers and suppliers are strong supporters of America’s veterans. For instance, Jaguar Land Rover North America launched the Land Rover Veterans Careers Program to connect ‘skilled and experienced transitioning service members and veterans with positions across the Jaguar Land Rover retail network.’ Mercedes-Benz was the first luxury automotive manufacturer to partner with the U.S. Department of Labor and Department of Veterans Affairs to offer a Registered Apprenticeship Program. This apprenticeship program prepares veterans and transitioning servicemembers for in-demand technician careers at authorized Mercedes-Benz dealerships.”


“Given that cross-border automotive trade and investment takes place between the United States and most of our key, long-term allies, it would be a grave mistake to impose tariffs on the sector based on the Department’s alleged, yet indeterminate, national security concerns.”