Magna International Letter To The U.S. Department of Commerce
Magna International was among several foreign-owned Upstate manufacturers to weigh in recently on the Trump administration's investigation of the auto industry and whether imports affect national security. A hearing in Washington, D.C., will take place July 19 and 20.
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Magna International Letter To The U.S. Department of Commerce
Magna International was among several foreign-owned Upstate manufacturers to weigh in recently on the Trump administration's investigation of the auto industry and whether imports affect national security. A hearing in Washington, D.C., will take place July 19 and 20.
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MA MAGNA
June 29, 2018
VIA REGULATIONS.GOV PUBLIC DOCUMENT
Hon. Wilbur L Ross, J.
Secretary of Commerce
‘Attention: Section 232 Automobile and
‘Automotive Parts Imports Investigation
USS, Department of Commerce
‘4th and Constitution Avenue, NW
‘Washington, D.C. 20230
Re: Notice of Request for Public Comments and Public Hearing on Section 232 National
Security Investigation of Imports of Automobiles, Including Cars, SUVs, Vans and Light
‘Trucks, and Automotive Parts; Docket No, DOC-2018-0002,
Dear Secretary Koss,
‘As the largest automotive supplier in the U.S. and North America, Magna International Magna)
‘strongly opposes any tariffs, quota restrictions, or other adjustments to imports of automebiles oF
‘automotive parts. Ifthe current Section 232 investigation regarding automobiles and automotive
parts results in such taifs, quotas, or adjustments, & wil ieversibly harm American businesses,
Workers, and consumers
‘At Magna, our worldwide reach includes 172,000 employees in our 340 manufacturing and @3
‘product development, engineering, and sales centers. We employ 27,125 people in our 58 U.S.
‘manufacturing operations and 13 product development, engineering, and sales centers in 11
sates. Since 2011, Magna has created more than 8,400 U.S. jobs, As such, we are keenly aware
of the needs of Americans,
(Over the past decade, the U.S. automotive industry has experienced significant growth, tis not
{an industy in decline. More than 87,000 Americans are employed by motor vehicle parts
‘manufacturers, a 19% increase from 2012, representing 2.9% of the total U.S. employment
‘market. The total employment impact ofthe motor vehicle parts manufacturing industy inthe U.S.
's 4.26 milion, which represents an 18% increase from 2012. Neatly $435 bili in economic
Contribution to the U.S. GDP is generated by automotive parts manufacturers and supported
‘activity. In foal, automotive parts suppliers contribute more than 77 percent ofthe value in today's
Vehicles, which exemplifies the strength and importance ofthe automotive supply chain,
Innovation, job creation, and an integrated supply chain do not presenta threat to the economic
secunty of the United States. The imposition of tarts or other trade bariers on importedPapen
‘automobiles andior automotive parts would weeken the U.S, economy and threaten to undermine
the entre U.S. automotive industry, puting American global competitiveness at risk and making
the U.S. a less attractive place to invest, For example, the automotive industry ison the cusp of
transformative innavations in advanced safety, efficiency, and aulomated technovogies, which
Fequire substantial development costs. However, this current and future development depends
fon the free flow of trade for new and state-of-the-art parts, systems, and raw materials. Limiting
access to these components wil increase costs in the U.S. and make other regions ofthe world
more attractive foruture investment.
Tariffs would also introduce @ significant amount of uncertainty into the marketplace, which is
especially harmful to a capitalintensive industry such as automotive. As seen with the
‘announcement of steel and aluminum tariffs in March 2018, business planning and forecasting
becomes extremely dificult. Not only do production and administrative costs rise inthe United
States, but the international community imposes ts own reciprocal measures to counterbalance
the tariffs. Indeed, the global response to steel and aluminum tariffs has been both swift and
significant. Retaliatory tarfs have already taken effect in Mexico and China, and soon Canada
and the European Union will implement additional tars,
Ifthe United States imposes a tariff on automobiles andior automotive parts, costs for US.
‘operations would grow exponentially. Utimately, businesses, both large and small, American
‘automotive workers, and consumers would be directly harmed. Accardng tothe Peterson Insite
{or international Economics, if the U.S. imposes a 25 percent duty on all imports of automobiles
‘and automotive pats, and other countries retaliate with in-kind tars, it would reduce production
by 4 percent, 624,000 USS. jobs would be lost, and consumers would pay higher prices for bth
Imported and domestically produced vehicles
We urge you to recommend no action on the Section 232 investigation Into automobiles and
‘automotive parts. Furthermore, our company is @ member of the Motor & Equipment
‘Manufacturers Associaton, and we endorse the comments fled by MEMA. Rather than protect
the economic secunty of the U.S. tanffs would undermine the currently thriving automotive
industry and directly harm the millons of Americans @t employs