July 24, 2017 The Honorable Donald J. Trump President of the United States The White House 1600 Pennsylvania Ave., NW Washington, D.C. 20500

Re: Section 232 National Security Investigation of Imports of Aluminum

Dear Mr. President:

We write to you regarding the Presidential Memorandum to the Secretary of Commerce, dated April 27, 2017, which directs an “investigation under section 232(b)(1)(A) of the Trade Expansion Act of 1962… to determine the effects on national security of aluminum imports.” Our industries produce nearly 96 billion beverage and food cans annually, employing tens of thousands of American workers, with the majority of these cans are made from primary aluminum. The total impact of aluminum beverage can and bottle production, along with the beer and soft drink industries, is $74.5 billion annually and directly employs over 82,000 American workers. We appreciate your commitment to America’s security and to assuring a level playing field for American manufacturing. However, we are concerned that the scope of this investigation will include aluminum that has no national security application, such as rolled can sheet and the primary aluminum which is processed into aluminum food, beverage cans and bottles, lids and closures. The manufacturers of aluminum food, beverage cans, and aluminum bottles use recycled aluminum, scrap aluminum and imported primary aluminum. Primary aluminum used in cansheet is not widely available in the United States because U.S. aluminum smelters choose to produce other alloys that are more profitable. As a result, primary aluminum made into rolled can sheet must be sourced from outside the United States, and American companies that use these products depend on these imports. Any import restrictions or tariffs on these products will add hundreds of millions in costs for companies in the food and beverage industry and will detrimentally affect over 82,000 American manufacturing jobs in industries that rely on these products. Finally, we are concerned that any import restriction on these types of aluminum will result in retaliatory action by other countries on American exports – such as American scrap metal and American agricultural products. Specifically, we ask that the following products, along with primary aluminum, be excluded from the 232 consideration:

x Aluminum cansheet bodystock - 7606.12.3045; x Aluminum can lid stock - 7606.12.3055; x Other aluminum cansheet - 7606.12.3090; x Aluminum used beverage container scrap - 7602.00.0030 x Aluminum waste and scrap other than used beverage container scrap -

7602.00.0090 x Aluminum slugs: 7616.99 and 7606.91; and x Low purity (non-military) aluminum ingot - 7601.10.6000.

THE HONORABLE DONALD J. TRUMP PAGE 2

We know it is not your intent to harm one industry for the benefit of another, which is why, in the interest of American workers and consumers, we urge you to exclude these materials from a tariff or any other restrictions. Thank you for your leadership in supporting American industry. We look forward to resolving this issue and making American manufacturing and our economy great again. Sincerely,

Pamela Bailey President & CEO Grocery Manufacturers Association Washington, DC

Alexander Barth Chief Executive Officer John I. Haas, Inc. Washington, DC

Robert Budway President Can Manufacturers Institute Washington, DC

Albert P. Carey Chief Executive Officer PepsiCo North America Purchase, NY

Kelly Clay Chief Executive Officer Admiral Beverage Corporation Worland, WY

Ralph D. Crowley, Jr. President & CEO Polar Beverages Worcester, MA

Matthew Dent President & COO Buffalo Rock Company Birmingham, AL

J. Alexander M. (Sandy) Douglas President Coca-Cola North America The Coca-Cola Company Atlanta, GA

Tim Donahue President & CEO Crown Holdings Philadelphia, PA

Ronald den Elzen President & CEO Heineken USA White Plains, NY

Paul Finney President & CEO Pepsi Bottling Ventures, LLC Raleigh, NC

Steve Ford President & CEO LinPepCo Partnership Lincoln, NE

Jerry Fowden Chief Executive Officer Cott Corporation Tampa, FL

Mark Francoeur President Coca-Cola Bottling Company of

Northern New England Bedford, NH

Louis S. Gimbel, 4th Chief Executive Officer S. S. Steiner, Inc. New York, NY

William Hackett Chairman Constellation Beers Chicago, IL

Sally Hargis Chairman of the Board Ozarks Coca-Cola/Dr Pepper

Bottling Company Springfield, MO

J. Frank Harrison, III Chairman & CEO Coca-Cola Bottling Company

Consolidated Charlotte, NC

THE HONORABLE DONALD J. TRUMP PAGE 3

John Hayes Chairman, President & CEO Ball Corporation Broomfield, CO

Jeff Honickman Chief Executive Officer Pepsi-Cola & National Brand

Beverages, Ltd. Pennsauken, NJ

Mark Hunter President & CEO Molson Coors Brewing Company Milwaukee, WI

Brett Joyce President Rogue Ales Portland, OR

C. James Koch Chairman of Boston Beer Company Sam Adams Boston, MA

Jeffrey S. Laschen Chief Executive Officer Great Lakes Coca-Cola Rosemont, IL

Claude Marbach CEO, Metal Beverage North America Ardagh Group Chicago, IL

Jim McGreevy President & CEO Beer Institute Washington, DC

Susan K. Neely President & CEO American Beverage Association Washington, DC

Claude B. Nielsen Chairman of the Board Coca-Cola Bottling Company

United, Inc. Birmingham, AL

João Castro Neves President & CEO Anheuser-Busch St. Louis, MO

Bob Pease President & CEO Brewers Association Washington, DC

John “Jack” E. Pelo President & CEO Swire Coca-Cola, USA Draper, UT

Craig Purser President & CEO National Beer Wholesalers

Association Washington, DC

Troy Taylor Chairman & CEO Coca-Cola Beverages Florida, LLC Tampa, FL

Larry Young President & CEO Dr Pepper Snapple Group Plano, TX

The U.S exports CANSHEET to Mexico and Canada. A tariff or import restriction on PRIMARY ALUMINUM would increase the cost of American CANSHEET and harm American exports.

The U.S. depends ENTIRELY on imported bauxite to produce PRIMARY ALUMINUM. It is NOT available in the U.S. in commercially viable quantities or quality.3

1 On April 27, 2017 President Trump prioritized an investigation previously initiated by the Secretary of Commerce into whether aluminum imports threaten the economic and national security of the United States. The investigation is being conducted under Section 232 of the Trade Expansion Act of 1962. The military, however, relies on high purity aluminum grades, which account for only 2% of overall U.S. primary aluminum product consumption. This is a different material than what is used to make aluminum beverage cans.

2 Cans are the most sustainable packaging. They are infinitely recyclable and remade into new cans within 60 days. 3 Why does the U.S. depend on imported PRIMARY ALUMINUM? The aluminum production process starts with the mining of bauxite. The U.S. has been in a deficit position with respect to primary aluminum since the end of WWII. As domestic production has decreased over the years, consumption has increased. The U.S. aluminum smelting industry is not competitive globally due to higher energy costs, old technology, ample domestic scrap availability and a strong U.S. dollar. Despite decreased production, U.S. smelters are cash positive at current aluminum prices. Today, even if all available smelters were running at full capacity, the U.S. would still have to import 83% of the total primary aluminum to meet demand. 4Products in these Codes should be exempt from import adjustments: 7606.12.3045, 7606.12.3055, 7606.12.3090, 7602.00.0030, 7602.00.0090, 7606.92.3090, 7601.10.6000, 7616.99 and 7606.91.

Aluminum CANSHEET Facts The Impact of Tariffs Under Section 232 of the Trade Expansion Act1

The following should be exempt4 from any import adjustments under Section 232: Cansheet | Body Stock | Aluminum Used Beverage Container Scrap | Aluminum Slugs | Low Purity Ingot

66% of PRIMARY ALUMINUM imported into the US, comes from Canada. No other country accounts for more than 10%. The U.S. does NOT import primary aluminum from China.

CANSHEET is made from:

Even though 98% of the CANSHEET used to make beverage cans in the U.S. is produced domestically, a modest, targeted tariff on the 2% of imported CANSHEET would incentivize a broad-based rise in aluminum prices.

66%

Other Ally Countries

Even a 1¢ increase per can -- as a result of a tariff -- will cost the can industry $960 million which could lead to lost U.S. jobs and increased costs to consumers.

Recycled Cans2 +

Scrap Metals +

PRIMARY ALUMINUM

70%

30%

THE ECONOMIC IMPACT OF THE

ALUMINUM CAN PRODUCTION:

96 BILLION CANS

BEVERAGE | FOOD | AEROSOL

8,488 JOBS

23 STATES

$9.2 BILLION

ECONOMIC OUTPUT

52 PLANTS

ECONOMIC OUTPUT

$28.6 BILLION

More than HALF of

produced is packed in ALUMINUM

BOTTLES or CANS

beer

ALUMINUM BEVERAGE CAN PRODUCTION

SOFT DRINK PRODUCTION IN CANS

BEER PRODUCTION IN CANS

ALUMINUM CAN INDUSTRY IN THE UNITED STATES

Source: John Dunham & Associates

33,667 JOBS

ECONOMIC OUTPUT

$34 BILLION

40,666 JOBS

TOTAL IMPACT

ECONOMIC OUTPUT

$71.8 BILLION

OF THE BEVERAGE CAN, BEER & SOFT DRINK INDUSTRIES

TOTAL JOBS

82,821

MORE THAN HALF OF

PRODUCED IS PACKED IN ALUMINUM

BOTTLES or CANS