Competitive MDI Coalition
November 13, 2019
The Honorable Robert E. Lighthizer
United States Trade Representative
Office of the U.S. Trade Representative
600 17th Street, NW
Washington, DC 20508
Dear Ambassador Lighthizer:
As members of the Competitive MDI Coalition, we write to ask you to exclude polymethylene
diphenyl diisocyanate (PMDI) and crude methylene phenyl isocyanate (Crude MDI) from the
Section 301 tariffs. As substantial consumers of PMDI, an important input throughout our U.S.
manufacturing operations in 14 states employing collectively more than 1,000 people, we
strongly believe a competitive and robust supply of these products is essential for U.S.
manufacturing and building industries and the United States’ continued economic growth.
PMDI is used in U.S.-manufactured energy-saving insulation and other U.S.-manufactured
building materials. PMDI is the main component of spray polyurethane foam insulation, a
leading insulation technology for residential and commercial buildings. It is also the main input
for foam insulation board and insulated metal-faced panels, which achieve high energy
standards, fire-safety, and simplified construction methods via factory-made panels for
residential and commercial construction. For example, 80 to 90 percent of all commercial
roofing insulation systems manufactured in the United States are made with PMDI. PMDI is
also increasingly replacing other binders in U.S.-manufactured building materials like composite
wood products (“CWP”), which include particle board and medium density fiberboard, and in
recycled rubber crumb playground and sports track surfaces at schools and parks across the
country.
There is a shortage of PMDI in the U.S. market. Current U.S. production of PMDI cannot meet
the growing demand of the U.S. market which is driven by expanding uses for PMDI through the
innovation and efforts of companies like ours. The shortfall in U.S. production capacity is
forecast to continue through at least 2021. Lack of availability and other constraints prevent
alternative sources of supply from meeting U.S. demand. As a result, the ability to import this
product without extraordinary tariffs is essential. While some of us are competitors, we all
believe a robust, competitive market for PMDI is in the best interest of U.S. manufacturers like
us and is critical to supporting building projects and other industries across the United States. It
is for the same reasons that we also support exclusion of Crude MDI from the Section 301 tariffs.
While Crude MDI is not a commercially available product that we purchase, it is the feedstock
the import of which will spur the future development of expanded U.S. production capacity for
PMDI, which will eventually reduce the need for PMDI imports and further ensure our access to
this critical product.

 We cannot emphasize enough the adverse impact the tariffs on such a critical input will have on
our U.S. manufacturing of downstream products. Exclusion requests on these products are now
pending at USTR and can be found by Docket Request ID USTR-2019-0005-33409 (Crude
MDI) and USTR-2019-0005-35272 (PMDI). We urge that they be granted.
Sincerely,

Atlas Roofing Corporation
Carlisle Construction Materials
Johns Manville
Polyisocyanurate Insulation Manufacturers Association
Stockmeier Urethanes
SWD Urethane Company
Wanhua Chemical US Operations LLC.
Weyerhaeuser Company

CC: Charles Grassley, Chairman of the Senate Finance Committee
Ron Wyden, Ranking Member of the Senate Finance Committee
Richard Neal, Chairman of the House Ways and Means Committee
Kevin Brady, Ranking Member of the House Ways and Means Committee
Earl Blumenauer, Chairman of the Ways and Means Subcommittee on Trade
Vern Buchanan, Ranking Member of the Ways and Means Subcommittee on Trade