American Iron and Steel

​​EPA requires the Owner to demonstrate products and items covered under the AIS regulations are in conformance.  Owners can demonstrate conformance using either Step Certification or Final Manufacturer Certification methods.

• Step Certification:  Requires each handler (supplier, fabricator, manufacturer, processor etc) of the iron and steel products in certifies that their step in the process was domestically performed.  Each time a step in the manufacturing process takes place, the manufacturer delivers its work along with a certification of its origin.

• Final Manufacturers Certification:  Requires the final manufacturer that delivers the iron or steel product to the worksite, vendor, or contractor may provide a certification asserting that all manufacturing processes occurred in the United States.

Five Minimum Requirements for Information to include in an AIS Certification:

1. Name of Manufacturer (Note:  Should appear in the text of the letter and be on the company letter head.)

2. The location of the manufacturing facility where the product or process took place (not its headquarters)

3. A description of the product or item being delivered

4. A named project / location that the product was delivered to

5. A signature by a manufacturer's responsible party

Example of Manufacturer Certification 

​​There are two types of of waivers national waivers that are available for any project to use and project specific waivers.

1.  National Waivers (Two most typically used linked below).

• De Minimus Waiver 

• Minor Components Waiver
  

2. Project Specific Waivers

• Public Interest Waiver: Applying AIS would be inconsistent with the public interest.

• Example of Public Interest Waiver 

• Availability Waiver: Iron and Steel products are not produced in the United States in sufficient and reasonably available quantities and of a satisfactory quality.

• Example of Availability Waiver 

• Expense Waiver: Inclusion of Iron and Steel products produced in the United States will increase the cost of the overall project by more than twenty five percent. No example issued

• ​EPA AIS Guidance, Questions and Answers, Training, and Waivers