Disaggregated Analysis of Competitiveness and Employment Issues 

in Energy-Intensive Trade-Exposed Sectors 

by Michael W Nicholson 

Office of Competition and Economic Analysis 

June 2010 

Manufacturing and Services Economics Briefs are produced by the Office of Competition and Economic Analysis of 

the International Trade Administration’s Manufacturing and Services unit. A complete list of reports, along with 

links to other trade data and analysis, is available at www.trade.gov/mas/ian. 
Manufacturing and Services Economics Brief No. 1 

ii Disaggregated Analysis of Competitiveness and Employment Issues – June 2010

Acknowledgements 

I am happy to thank Joan Shipps, Jeffrey Anspacher, James Bradbury, Stefan Osborne, 

Joseph Flynn, Skip Jones, Leila Odom, and participants at the February 2010 research workshop 

on carbon policy analysis hosted by Resources for the Future for their helpful comments. The 

International Trade Administration’s Office of Materials Industries provided valuable 

background information on the steel industry. Brandon Thurner provided exceptional research 

assistance. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues iii 

Table of Contents 

 

Acknowledgements ......................................................................................................................... ii

Table of Contents ........................................................................................................................... iii

Executive Summary ........................................................................................................................ v

1. Introduction ................................................................................................................................ 1

2. EITE Employment ..................................................................................................................... 3

3. Trade and Competitiveness by EITE Sector and Partner ........................................................... 6

4. NAICS 331111 and the Steel-Making Process .......................................................................... 9

5. Modeling Exercises .................................................................................................................. 16

6. Suggested Future Work............................................................................................................ 18

References ..................................................................................................................................... 19

Appendix ....................................................................................................................................... 21

Table of Tables 

Table 1: Number of Employees by 6-digit NAICS (2007 Economic Census) .............................. 4

Table 2: Iron & Steel Employees, 7-digit NAICS (2002 Economic Census) .............................. 11

Table 3: Employees by Steel-Making Process, 2002 ................................................................... 14

Table 4: 10-Digit HTS Iron and Steel Exports by 7-digit NAICS ($1,000’s), 2002 ................... 15

Table 5: Potential employment changes based on H/M/S (2008) estimates ................................ 17

Table of Figures 

Figure 1: EITE employment within 3-digit NAICS ...................................................................... 5

Figure 2: Employment levels 1958-2005 ....................................................................................... 6

Figure 3: BICSA and U.S. Total Emissions Levels ....................................................................... 7

Figure 4: Iron and Steel Product Classes: Exports and Employees ............................................. 16

 
Manufacturing and Services Economics Brief No. 1 

iv Disaggregated Analysis of Competitiveness and Employment Issues – June 2010

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International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues v 

Executive Summary 

This paper presents and interprets key data on the potential international trade impacts – 

and consequent impacts on employment – of a change in energy input prices resulting from 

carbon emission reduction strategies. The report incorporates disaggregated data with a specific 

focus on the Iron and Steel sector. Key findings include: 

• Relative share of U.S. employment in the presumptively eligible energy-intensive, 

trade-exposed (EITE) sectors is most salient in the broad sectors of “Paper”, 

“Chemicals”, “Nonmetallic Mineral Products”, and “Primary Metal 

Manufacturing.” 

• Relative share of U.S. trade in the EITE sectors, particularly with respect to “Non 

Annex I” countries (as defined following the Kyoto Protocol) and “BICSA” 

countries (Brazil, India, China, and South Africa) is highest in the Chemicals and 

Iron and Steel sectors. 

• Disaggregated data on employment and trade in Iron and Steel may provide 

insight into employment reallocation. Employment in Iron and Steel has been 

steadily decreasing for 50 years and over the past 30 years, the majority of 

employment and establishments for the U.S. steel sector has shifted from highenergy-intensive integrated process production to less-energy-intensive 

“minimills.” 

• Existing economic analysis suggests small effects on employment following 

simulations of the effect of higher energy input costs resulting from strategies 

proposed to lessen potential impacts of climate change. Valuable information 

could be obtained from similar studies using the disaggregated data presented in 

this paper. 

 
Manufacturing and Services Economics Brief No. 1 

vi Disaggregated Analysis of Competitiveness and Employment Issues – June 2010

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International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 1 

1. Introduction 

This paper discusses the potential impact on U.S. employment and competitiveness of 

changes in energy-input prices resulting from strategies to mitigate carbon emissions.1

 We 

present key data on potential domestic effects and international trade shifts that could be affected 

by changing energy costs, while interpreting multiple charts that show the relative share of U.S. 

exports in the energy-intensive, trade-exposed (“EITE”) sectors. We also provide successive 

levels of disaggregation with regard to more specific sub-sectors within Iron & Steel, based on 

both their share of U.S. trade and the relative importance of large, developing countries such as 

Brazil, India, China, and South Africa (“BICSA”).2

 These countries emerged as a negotiating 

bloc on in the wake of climate change mitigation discussions in Copenhagen in 2009. 

The present research joins a slate of recent papers investigating the potential impact of 

energy-input price changes in the United States resulting from carbon-emission reduction 

strategies on EITE industries. The U.S. Commerce Department contributed to an interagency 

report on international competitiveness in EITE sectors in response to a specific letter drafted by 

five U.S. Senators representing states with large manufacturing sectors.3 The Interagency Report 

analyzed anticipated strategies to mitigate the potential impact resulting from restrictions on 

carbon emissions proposed in H.R. 2454 (“Waxman-Markey”). This paper delves further into 

the potential impacts of changes in energy-input prices, focusing on disaggregated employment 

and trade data within the Iron and Steel sector. It also analyzes patterns of international trade 

 

1

 The term “competitiveness” refers to the concept described by Ho, Morgenstern, and Shih (2008) in that “the 

strength of competition from imports and consumers’ ability to substitute other, less carbon-intensive alternatives for 

a given product play crucial roles in determining the ultimate impacts of domestic production and employment.” 

2

 These countries have also been referred to as BASIC – see, for example, Financial Times on January 19, 2010 and 

Washington Post on February 10, 2010. The BICSA references “BRIC” (Brazil, Russia, India, and China), with the 

inclusion of South Africa and the exclusion of Russia. Russia may be excluded in this context for two key reasons: 

first, it signed Kyoto and second, Russia registered the largest absolute drop in emissions from 1990 levels than any 

other Kyoto Protocol signatory (see Washington Post November 30, 2009). For these reasons also, Russia may play 

a unique and important role in climate negotiations, included in the Section 4 discussion below. 

3

 “The Effects of H.R. 2454 on International Competitiveness and Emission Leakage in Energy-Intensive TradeExposed Industries,” December 2, 2009, herein referred to as “The Interagency Report.” See: 

http://epa.gov/climatechange/economics/pdfs/InteragencyReport_Competitiveness-EmissionLeakage.pdf. Other 

agencies included: Energy Information Administration, Treasury Department, Environmental Protection Agency, 

National Economic Council, Office of Management and Budget Council on Environmental Quality, Council of 

Economic Advisors, Office of Energy and Climate Change. The U.S. International Trade Commission provided 

assistance with technical modeling. Signatories to the letter include: Sen. Evan Bayh (Indiana), Sen. Arlen Specter 

(Pennsylvania), Sen. Debbie Stabenow (Michigan), Sen. Claire McCaskill (Missouri), and Sen. Sherrod Brown 

(Ohio). 
Manufacturing and Services Economics Brief No. 1 

2 Disaggregated Analysis of Competitiveness and Employment Issues

demarcated by the BICSA countries. 

The paper proceeds as follows. Section 2 presents key data on sector-specific 

employment, recognizing that the relative sensitivity between domestic manufacturing sectors to 

the changes in the price of energy intensive inputs such as electricity could create substantial 

labor displacement in the U.S. economy. Section 3 interprets data on EITE-related trade by 

major economic partners, presenting data that recognizes key climate change negotiating blocs, 

such as signers of the 1997 Kyoto Protocol, and the large, developing countries of BICSA. To 

the extent that carbon-emission strategies in the United States are matched by similar actions in 

other countries, the trade effects associated with these actions will be muted. Because the main 

mitigation strategies under consideration now that affect energy prices are to control carbon 

emissions, it makes sense to consider which U.S. trading partners are likely to take similar 

action. Kyoto signatories are commonly referred to as “Annex I” countries, as defined in the 

agreement as industrialized countries and economies in transition.4 Countries that have not 

signed the Kyoto agreement, or developing countries that have signed Kyoto but were not 

required to reduce emissions (the “Non-Annex I” countries), might be considered the least likely 

to match U.S. action on carbon emissions reductions, so the exposure of EITE industry to trade 

from these countries are particularly relevant. 

EITE sectors are defined at the 6-digit NAICS5 level, which may mask underlying 

impacts found at further levels of disaggregation, particularly within the steel industry. For 

example, NAICS industry 331111 is defined as “Iron and Steel,” disaggregated from the 3-digit 

NAICS industry 3311 “Iron, Steel, and Ferroalloy.” Section 4 analyzes employment and 

competitiveness figures at disaggregated levels within Iron and Steel, including 7-digit NAICS 

“product classes,” 7-digit NAICS production processes, and 10-digit HTS6

 trade patterns. 

Section 5 presents estimations from modeling exercises that suggest the size of employment risk 

in various sectors. The paper concludes with recommended areas of research. 

 

4

 The 40 Annex I countries include: Australia, Austria, Belarus, Belgium, Bulgaria, Canada, Croatia, Czech 

Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, 

Liechtenstein, Lithuania, Luxembourg, Monaco, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, 

Russian Federation, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom, United 

States. The European Union is also considered Annex I. 

5

 North American Industry Classification System. See: http://www.census.gov/eos/www/naics/. 6

 Harmonized Tariff Schedules. See http://hts.usitc.gov/. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 3 

2. EITE Employment 

The total number of jobs in all EITE sectors, based on 2007 Economic Census data, is 

780,844. Table 1 provides information about the number of jobs in 6-digit NAICS sectors 

potentially sensitive to changes in energy input prices.7 The total number of jobs at risk in EITE 

sectors represents less than 0.5 percent of the U.S. labor force8

 and less than 15 percent of jobs in 

their own 3-digit NAICS sectors. In all but four 3-digit NAICS sectors containing EITE 

industries, the vast majority of jobs are not in EITE industries. 

 

7

 Data from Table 1 and definitions of EITE sectors are culled from The Interagency Report.” 

8

 The Bureau of Labor Statistics estimated the U.S. labor force to be 153,124,000 in 2007, which has risen to 

153,911,000 in April 2010. See http://www.bls.gov/cps/lfcharacteristics.htm#laborforce. 
Manufacturing and Services Economics Brief No. 1 

4 Disaggregated Analysis of Competitiveness and Employment Issues

Table 1: Number of Employees by 6-digit NAICS (2007 Economic Census)

NAICS Description Employees NAICS Description Employees NAICS Description Employees 

212210 Iron Ores 5,189 325188 All Other Basic 

Inorganic 

35,801 327213 Glass Containers 14,928 

212234 Copper & 

Nickel Ores 

7,288 325192 Cyclic Crude & 

Intmdtes 

3,006 327310 Cements 17,749 

311213 Malts 1,022 325199 All Other Basic 

Organic Chem 

70,602 327410 Lime & Calcinated 

Dolomite 

4,369 

311221 Wet Corn 

Milling 

8,448 325211 Plastic Materials, 

Resins 

71,216 327992 Ground or Treated 

Mineral, Earth 

6,497 

311613 Animal Fats, 

Oils 

9,355 325212 Synthetic Rubbers 9,794 327993 Mineral Wool & 

Glass Fibers 

18,891 

313111 Yarns 24,750 325221 Cellulosic Organic 

Fibers 

1,353 331111 Iron & Steel 114,315 

314992 Tire Cords & 

Fabrics 

3,577 325222 Noncellulosic Organic 14,684 331112 Em Ferroalloy 2,144 

321219 Reconstituted 

Wood 

20,426 325311 Nitrogenous 

Fertilizers 

3,920 331210 Steel Wire Drawing 17,408 

322110 Pulp Mill 

Products 

7,268 327111 China Plumbing, 

Earthenware 

Bathroom 

4,825 331311 Alumina Refining 1,611 

322121 Paper Mill 75,921 327112 China, Fine 

Earthenware 

8,774 331312 Prim. Aluminum 9,355 

322122 Newsprint Mill 4,917 327113 Porcelain Electrical 4,465 331411 Secondary Smelting 

(Aluminum) 

1,771 

322130 Paperboard Mill 36,641 327122 Ceramic Wall & Floor 

Tiles 

6,272 331419 Other Aluminum 

Rolling, Drawing 

8,067 

325110 Petrochemicals 9,257 327123 Other Structural 

Ceramic 

1,650 331511 Iron Foundries 51,503 

325131 Inorganic Dyes 

and Pigments 

7,606 327125 Nonclay Refractory 5,338 335991 Carbon and 

Graphite Mfg 

8,666 

325181 Alkalies and 

Chlorine 

6,364 327211 Drawn, Blown, Float, 

Flat Glass 

10,991 Total 780,774 

325182 Carbon Black 1,591 327212 Other Pressed & 

Blown Glass 

21,189 

As shown in Figure 1, the share of EITE employment for three-digit sectors is highest in 

322 (Paper), 325 (Chemicals), 327 (Nonmetallic Minerals), and 331 (Primary Metal 

Manufacturing), which serves as the basis for analysis in subsequent sections of the paper. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 5 

Figure 1: EITE employment within 3-digit NAICS

In addition to low levels of employment relative to industry aggregates, employment in 

EITE sectors has been trending down for decades. Figure 2 shows select EITE employment 

from 1958-2005 with 331111 (Iron and Steel) represented by the blue (dashed) line, 331511 

(Iron Foundries) represented by the black (crossed) line, and 322121 (Paper Mills) represented 

by the red (flat) line.9

 Amongst these sectors, the highest level of employment was in Iron and 

Steel, topping a half-million employees in the 1960s before a substantial drop-off in the early 

1980s.10 Iron Foundries has been historically the second-highest employer, with 167,500 

employees as recently as 1980, while employment in Paper Mills has remained relatively 

constant over the entire time period. None of the other EITE sectors reached 100,000 employees 

in any year of the survey. 

 

9

 Becker and Gray (2009) accessed at http://www.nber.org/data/nbprod2005.html 10 Yudken and Bassi (2009) explain the large drop in employment by lost capacity and productivity improvements. 

‐

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

212

minerals and

ores

311

Food and

Kindred

Products

313

textiles and

fabrics

314

textile mill

products

321

wood products

322

paper

325

chemicals

327

nonmetallic

mineral

products

331

primary metal

manufacturing

335

electrical

equpment

EITE employment within 3‐digit NAICS

Non‐EITE

EITE
Manufacturing and Services Economics Brief No. 1 

6 Disaggregated Analysis of Competitiveness and Employment Issues

Figure 2: Employment levels 1958-200511

3. Trade and Competitiveness by EITE Sector and Partner 

One of the main issues associated with unilateral actions restricting carbon emissions is 

that higher energy input costs may cause U.S. production to shift to countries that have not 

matched the U.S. regulation. Such production shifts that result in lower global emissions 

reductions than otherwise would have occurred are referred to as “leakage.”12 The potential 

impact of proposed carbon-reducing strategies on energy prices and, consequently, on EITE 

industry production and employment plays a key role in identifying mitigating strategies that can 

address the leakage issue.

Regulation of carbon emissions could raise energy input costs in a manner that negatively 

impacts employment within EITE sectors by shifting production to lower-emitting domestic 

 

11 Becker and Gray (2009) accessed at http://www.nber.org/data/nbprod2005.html 12 See, among others, Hufbauer, Charnovitz, and Kim (2009). 

0

100,000

200,000

300,000

400,000

500,000

600,000

195819591960196119621963196419651966196719681969197019711972197319741975197619771978197919801981198219831984198519861987198819891990199119921993199419951996199719981999200020012002200320042005

Employment 1958‐2005

331111 (Iron and Steel) 

322121 (Paper Mills) 

331511 (Iron Foundries) 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 7 

sectors or to overseas countries without reciprocating carbon-emission restrictions.13 Negative 

impacts on competitiveness are manifested in international trade through diminished exports or 

by imports that substitute for domestic production. Table A-1 in the appendix ranks the EITE 

sectors according to their levels of employment; note that EITE sectors with the largest levels of 

employment also generally have large trade exposure.

Two of the three largest trading partners of the United States – Canada and Mexico – 

committed to reducing carbon emissions in the Kyoto Protocol. China, a “Non-Annex I” 

signatory to the Kyoto Protocol, did not. As shown in Figure 3, China and the BICSA countries 

are significant carbon emitters. China surpassed U.S. emissions levels in 2006, while BICSA as 

a group passed the United States in 2003. 

Figure 3: BICSA and U.S. Total Emissions Levels14

 

13 See, for example, Hufbauer, Charnovitz, and Kim (2009), The Interagency Report (2009), and Fischer and 

Morganstern (2009). 

14 Data provided by Energy Information Administration: International Energy Statistics 

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

BICSA and United States Total Emissions Levels (million metric tons)

United States

Brazil

India

China

South Africa

BICSA Total

BICSA 

Total

China

United States

India

Brazil, South Africa 
Manufacturing and Services Economics Brief No. 1 

8 Disaggregated Analysis of Competitiveness and Employment Issues

This section presents a series of charts that provide a visual representation of the potential 

impacts on competitiveness for U.S. industries due to export exposure in selected sectors across 

various regions with a particular emphasis on Non-Annex I countries and BICSA. Figures 

referenced in this section, shown in the appendix, parse the EITE sectors according to both their 

overall trade volume and the export share of BICSA countries to demonstrate relative exposure 

of U.S. domestic industries and potential impacts on competitiveness and employment. 

Appendix Table A-2 ranks the six-digit NAICS sectors according to the size of the 

volume of U.S. total exports, including information about the percentage of all exports in the 

sector to BICSA countries and the extent to which BICSA exports make up all Non-Annex I 

exports. The greatest total of exports are the same sectors – 322 (Paper), 325 (Chemicals), 327 

(Nonmetallic Minerals), and 331 (Primary Metal Manufacturing) – that were also shown in 

Figure 1 to have the largest share of employment. 

Figures F-1 to F-4, shown in the appendix, provide information about U.S. trade exposure 

in select EITE sectors based on key regional groups motivated by previous research and current 

negotiations.15 These figures use the following regions: Europe-32; Canada; Mexico; Annex I 

CIS16 (Russia); Other Annex I; BICSA; Other Non-Annex I. Europe-32 refers to the 32 non-CIS 

European countries that are Kyoto signatories (including Turkey). Canada and Mexico are 

separated due to their role as leading trade partners of the United States. The “Other Annex I” 

countries are New Zealand, Australia, and Japan. Of particular interest are both absolute trade 

shares of BICSA and the relative trade share of all non-Annex I countries in order to isolate 

country-source challenges to energy regulation. 

Figure F-1 shows the 2009 U.S. export and import shares, respectively, by 3-digit NAICS 

codes for EITE industries, with total volumes for the 3-digit sectors listed at the bottom. The 

BICSA countries represent from 9 percent to 18 percent share of exports and from 4 percent to 

34 percent of imports, while all non-Annex I countries represent from 21 percent to 43 percent 

share of exports and from 9 percent to 37 percent of imports. This figure shows large 

 

15 Fischer and Morganstern (2009) display the 2004 U.S. import shares of 3-digit manufacturing industries, 

demarcated by BrIC (Brazil, India, China), Other (Non-Annex I), Mexico, Canada, Europe, and Other Annex I. The 

Interagency Report produces a similar chart showing the distribution of 2008 U.S. international trade by origin and 

destination countries demarcated by the European Union, Other Annex I (Australia, New Zealand, Japan), Canada, 

Mexico, China, India, and “Other” (Non-Annex I). 16 Commonwealth of Independent States. Russia is represented with Belarus and Ukraine in “Annex I CIS.” Note 

that the values for this region are dominated substantially by Russia. The other CIS countries are included here 

rather than Europe due to their historical geo-economic integration with Russia. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 9 

percentages of imports in 212 (Minerals and Ores) but does not emphasize the total values of 

imports for the sectors, which are labeled at the bottom in $1,000’s. 

An alternative representation of exposure may be found in Figure F-2, which compares 

respective sizes of 4-digit NAICS sectors. 17 As shown, the trading landscape is dominated by a 

few 4-digit sectors, particularly 3221 (Pulp, Paper, and Paperboard), 3251 (Basic Chemicals), 

3252 (Resin and Synthetic Rubber), 3311(Iron and Steel and Ferroalloy), 3314 (Nonferrous 

Metal except Aluminum), and 3359 (Electrical Equipment). Note that some 4-digit sectors are 

heavily influenced by both exports and imports. This pattern holds at further disaggregated 

levels. Note also that the 4-digit EITE sectors with the largest total volumes also provide, in 

general, the largest shares of other non-Annex I volumes. 

To facilitate comparisons, Figures F-3 and F-4 present the breakdown of trading patterns 

for 6-digit EITE sectors within 3221, 3251, 3252, 3311, and 3314 using regional color-coding. 

Figure F-3 presents information about 3251 (Basic Chemicals) and 3252 (Resin, Synthetic 

Rubber, etc), the chemical sectors that dominated Figure 2 in terms of volume of exports. Note 

that the vertical axis measures over $30 billion in total volume of U.S. exports. The United 

States exports more than $1 billion in 325188 (Other Basic Inorganic) and over $4 billion in 

325199 (Other Basic Organic Chemicals) and 325211 (Plastics and Resins). 

Figure F-4 presents information for 3221 (Pulp, Paper, and Paperboard), 3311 (Iron and 

Steel and Ferroalloy) and 3314 (Nonferrous Metal except Aluminum). The figure suggests that 

salient sectors for analysis are 322121 (Paper Mill), 331111 (Iron and Steel), and 331419 (Other 

Aluminum Rolling and Drawing). The next section disaggregates Iron and Steel data. 

4. NAICS 331111 and the Steel-Making Process 

Steel production can be broadly characterized by two major processes: Basic Oxygen 

Furnace (BOF), also known as “integrated mills”, and Electric Arc Furnace (EAF), or 

“minimills.” Integrated Mills make iron in a blast furnace using processed coal, or “coke”, as a 

 

17 The number below the sector description is the percentage of exports accounted by the BICSA countries; the only 

two that represent more than 20% of the market for U.S. exports, 3253 (Agricultural Chemicals) and 3315 

(Foundries) account for a total of only $1.7 billion in trade. The number below the sector description is the 

percentage of imports accounted by the BrIC countries; the largest of these, 51% in 3315 (Electric Lighting 

Equipment) only represents about $500,000 worth of imports, whereas, as shown below, BrIC imports in the 6-digit 

sector 331111 (Iron & Steel) alone tops $11 billion. These numbers do not provide information about relative 

intensity of carbon emissions in particular sectors. 
Manufacturing and Services Economics Brief No. 1 

10 Disaggregated Analysis of Competitiveness and Employment Issues

main energy source, and then the basic oxygen furnace converts the iron into steel. Electric 

furnaces, on the other hand use mostly recycled steel (“ferrous scrap”) and electricity to create 

steel; over the last decade, EAF steel production has increased from 43 percent to 58 percent of 

the U.S. total. 

The BOF process yields substantial amounts of direct emissions, while the EAF process 

yields primarily indirect emissions through its use of electricity as a main input. The 6-digit 

NAICS representation does not demarcate according to production process. Accordingly, 

legislation such as H.R. 2454 considers entities using “integrated iron and steel making 

technologies including coke ovens, blast furnaces, and other iron-making technologies” 

(integrated/BOF) and “entities using electric arc furnace technologies” (minimill/EAF) to be in 

the same eligible industrial sector; however, the Interagency Report, drafted in direct 

consideration of proposals in H.R. 2454, points out that the proposed domestic climate change 

legislation recognizes the different production processes (integrated/BOF versus minimill/EAF) 

as separate sectors for determining allocation rates for mitigating strategies. That is, the two 

production processes are part of the same EITE sector but may be eligible for different 

allocations based on their energy intensity. 

Data on steel-making production processes may be gleaned from the five-year Economic 

Census reports. The 6-digit NAICS classification officially provides the most specific industry 

information, the Economic Census supplements this information with 7-digit NAICS “product 

classes.” Employment information at the level of product class has not yet been produced for the 

2007 Economic Census, so Table 2 provides information about employment at the 7-digit 

NAICS classification from the 2002 Economic Census. As can be seen, the largest employment 

within the 6-digit “Iron and Steel” sector is 3311115 and 3311117, generically “hot rolled steel,” 

for a total of 81,129 employees. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 11 

Table 2: Iron & Steel Employees, 7-digit NAICS (2002 Economic Census)18

NAICS Meaning of Products and services code Employees 

# Corresponding 

HTS codes 

3311111 Coke oven and blast furnace products, made in steel mills 4,933 358 

3311113 Steel ingots and semifinished shapes and forms, steel mills 7,531 358 

3311115 Hot rolled steel sheet/strip (incl. tinplate/etc.), steel mills 51,146 358 

3311117 Hot rolled steel bars/bar shapes/plates/piling/etc., steel mills 29,983 358 

331111B Steel pipes/tubes, steel mills prod. semifinished shapes/plate 6,334 358 

331111D Cold rolled steel sheet/strip, steel mills/hot roll. sheet/strip 9,259 358 

331111F Cold fin. steel bars/shapes, steel mills/hot rolled bars/etc. 3,292 358 

331111L Other steel mill products, incl. steel rails, exc. wire products 3,131 358 

331111H Seamless rolled ring forgings, ferrous, made in steel mills 20-99 76 

331111J Open die & smith forgings (hammer/press), ferrous, steel mills 1000-2499 76 

3311119 Steel wire, including galvanized & other coated wire, steel mills 778 29 

Total: 118,847 

Pierce and Schott (2009) develop a concordance between the 7-digit NAICS “product 

classes” and 10-digit HTS codes. As Pierce and Schott point out, a primary challenge for such a 

concordance is the “many to many” problem, in which multiple 7-digit NAICS (or 5-digit SIC) 

codes correspond to multiple 10-digit HTS codes. The 7-digit NAICS codes 3311111, 3311113, 

3311115, 3311117, 331111B, 331111D, 331111F, and 331111J correspond to the same set of 

358 10-digit HTS codes, 331111H and 331111J correspond to another unique set of 76 10-digit 

HTS codes, and 3311119 represents its own 29 10-digit HTS codes. Unfortunately, no 

concordance is available to provide information about trading patterns for the different steelmaking processes. End users of steel products are indifferent as to whether they were created 

through blast-oxygen furnaces or electric arc “minimills” (except for possible price differentials), 

and trade data are classified according to end use. 

 The U.S. steel industry is the third largest in the world, behind China and Japan, with 

crude steel production of 102.2 million net tons in 2008, down from a high of 109.9 million tons 

during the previous economic cycle.19 Over the last decade, the U.S. share of world steel 

production has fallen sharply – from 12.7 percent to 6.9 percent – as production rose rapidly in 

 

18 http://factfinder.census.gov/servlet/IBQTable?_bm=y&-NAICS2002=331111&-ds_name=EC0231I5&-_lang=en

19 Yudken and Bassi (2009), pg 80, citing World Steel 2008 
Manufacturing and Services Economics Brief No. 1 

12 Disaggregated Analysis of Competitiveness and Employment Issues

developing countries, particularly China and India, where steel demand has been increasing. By 

contrast, in the United States, demand had been comparatively flat, before virtually collapsing 

after the 2008 financial crisis. However, the United States does not have the capacity to meet 

domestic demand and therefore relies on imports to supplement its domestic production. Over 

the last decade, import penetration has averaged over 20 percent, and while imports have fallen 

during the current recession, imports from China remain a serious concern for U.S. steelmakers, 

particularly given fluctuations in global steel markets.20 China’s steel producing capacity has 

more than doubled in recent years and now accounts for about half of total world steel 

production. 

The steel-making process offers a key narrative on competitiveness and leakage effects 

resulting from reduction of carbon emissions. Unilateral U.S. carbon reduction strategy that 

results in relatively higher coal prices (for the BOF process) and electricity prices (for the EAF 

process) could shift production overseas, resulting in job losses for the U.S. steel industry. To 

the extent that those countries rely more on the BOF process, overall global carbon emissions 

would actually increase. The regulatory action in this situation could potentially shift jobs out of 

the U.S. steel industry while increasing global carbon emissions. 

The U.S steel industry remains one of the largest energy consumers in manufacturing and 

could face substantial difficulties if faced with a steep rise in energy costs that might result from 

carbon emission reduction strategies. The impact across the industry would be uneven, with 

energy-intensive production by the integrated process particularly affected because of its heavy 

reliance on coal. Electric furnace operations would be squeezed, to a lesser extent, by higher 

electricity costs. 21 In Europe, BOF produces about 75 percent flat products and 25 percent long 

products, primarily for global markets, while EAF produces about 85 percent long products and 

15 percent flat products, mostly for regional markets.22 According to the U.S. Department of 

Energy, energy costs account for about 20 percent of the total cost to manufacture steel. Coke 

and coal accounted for about 38 percent of energy requirements, followed by natural gas (27 

percent), and electricity (13 percent). 

 

20 See Yudken and Bassi (2009), pg 85 

21 As previously noted, the BOF process yields substantial amounts of direct emissions, while the EAF process 

yields only indirect emissions through its use of electricity as a primary input. BOF products are primarily highvalue, cold-rolledflat products (see Carbon Trust 2004); EAF products are mainly long products for construction 

purposes (see McKinsey and ECOFYS 2006). 

22 McKinsey and ECOFYS (2006) 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 13 

 The competitiveness of electric furnace operations could be adversely affected by higher 

electricity costs resulting from higher costs of burning fossil fuels, given that estimated energy 

requirements to produce a ton of steel in an electric furnace are 675 KWh. The steel industry 

purchased 55 million kWh in 2008; the Steel Manufacturers Association estimates that 

steelmakers spend $3 billion for electricity in a typical year, including more than 64 percent by 

minimills.23

Bleischwitz, Fuhrmann, and Huchler (2007) compare the potential cost increases in the 

EU under a proposed carbon price of €20/ton of CO2.24 Given allowances and no pass-through 

of carbon costs, BOF could experience a cost increase of 16 to 17 percent, providing a clear 

incentive to shift production outside of any national or supra-national regions covered by the 

carbon price. 25 Under assumptions of 95 percent free allowances and pass-through of costs, the 

cost increases will be closer to 1 percent. McKinsey and ECOFYS (2006) estimate BOF steel 

producers might lose 1.7 percent of their revenue, and EAF producers 0.6 percent of revenue.26

 Because it is far more energy intensive, a substantial increase in energy costs would 

affect integrated steelmaking more than EAF production. A 2005 Department of Energy study 

estimated that the average energy intensity of the integrated process was nearly three times 

greater than EAF production (16.5 MBtu/ton vs. 5.7 MBtu/ton). Iron-making is particularly 

energy intensive. About 1.1 to 1.4 tons of metallurgical coal is required to produce one ton of 

coke. Integrated mills consumed 15.7 million tons of coke in blast furnaces (22.1 million tons of 

coal) to make iron in 2008. 

EAF steel is produced from scrap metal, which is currently scarce (or “bottlenecked”) on 

global market due to high demand in China.27 Because of this scarcity, the price of scrap metal 

is sufficiently high that EAF steel is not an economically viable replacement for BOF steel.28 

According to McKinsey and ECOFYS (2006), BOF steel faces continued issues of 

 

23 In a press release dated March 25, 2010, the American Iron and Steel Institute quotes industry representatives 

testifying before the U.S. Congress that EAF/minimill producers could face a potential doubling of electricity costs, 

possibly as high as $40/steel ton. 

http://www.steel.org/AM/Template.cfm?Section=Industry_News&TEMPLATE=/CM/ContentDisplay.cfm&CONTENTID=37653 24 Citing Huschler’s 2007 Master’s Thesis at the College of Europe, Bruges. 

25 The assumptions of allowances and no-pass-through recognize sector-specific mitigation strategies that have been 

proposed in Europe. “Pass-through” refers to the extent to which consumers bear the burden of increasing prices. In 

comparison, McKinsey and ECOFYS (2006) estimate that 6% of additional costs for BOF steel will be passed to 

consumers and 66% of EAF costs will be passed through. 

26 Revenue defined as Earnings Before Interests and Taxes (EBIT) 

27 See, among others, Yudken and Bassi (2009), pg 91. 

28 McKinsey and ECOFYS (2006) 
Manufacturing and Services Economics Brief No. 1 

14 Disaggregated Analysis of Competitiveness and Employment Issues

“debottlenecking” in the EU, where the capacity flow requires constant improvement. In the 

United States, according to Environmental Protection Agency (“EPA”) data, BOF production has 

declined from 70 percent of steel in 1985 to 45 percent in 2005. According to the American Iron 

and Steel Institute’s 2008 Annual Statistical Report, the share of BOF production continued to 

decline to 42.6percent in 2008, indicating a smaller share of a smaller market. 

 BOF steel is processed using iron and/or coal as inputs, the latter through coke ovens. A 

blast furnace yields a liquid “pig iron” which contains substantial carbon that is released in the 

blast oxygen furnace, yielding liquid steel.29 The EAF process also yields liquid steel from 

recycled materials such as scrap and iron ore. Table A-4, in the appendix, provides a chart with 

definitions according to the 1997 Economic Census for data on various steel-making processes. 

The same categories are used in the 2002 Economic Census but definitions are not provided. 

Based on these definitions of 7-digit NAICS steel-making, Table 3 provides information about 

employment in the various processes. No information is provided in the 2002 Economic Census 

for 331112, “Partially Integrated With a Blast Furnace.” 

Table 3: Employees by Steel-Making Process, 200230

NAICS Description Establishments Employees 

3311111 Iron & steel mills - fully integrated 9 32,740

3311113 Iron & steel mills - partially integrated without blast 

furnace 

48 25,769

3311114 Iron & steel mills - nonintegrated 316 60,338

Total: 373 118,847

We use HTS codes to gain substantive disaggregation within the Iron and Steel sectors by 

trading partners and regions. In general, the HTS classification system provides more 

disaggregated information than the NAICS classification system, and 4-digit HTS codes provide 

more disaggregation than 6-digit NAICS codes. Table A-3, listed in the appendix, ranks 4-digit 

HTS Iron and Steel industries by the size of their exports to BICSA countries. 

 

29 Significantly higher carbon costs may encourage integrated mills to shift production from energy-intensive iron 

and steel making facilities to imported semi-finished steel (“slabs”) to supply their rolling mills, which are less 

energy intensive. 

30 2002 Economic Census 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 15 

In a similar vein, Table 4 breaks down Iron and Steel exports by their 10-digit 

classification as established in Table 2 above. Set (i) refers to the first set of 7-digit NAICS 

product classes, with 358 corresponding HTS codes; set (ii) refers to the second set, with 72 

corresponding HTS; and set (iii) refers to the third set of the table, with 29 corresponding HTS. 

Trade with BICSA countries is only 3 percent in the listed data, with barely 10 percent of trade 

with Non Annex I countries. 

Table 4: 10-Digit HTS Iron and Steel Exports by 7-digit NAICS ($1,000’s), 200231

 Total BICSA NonAnnex I Canada CIS (Russia) Europe - 32 Mexico Other 

Annex I 

Set (i) $4,495,397 $118,808 $591,781 $2,231,868 $18,588 $427,162 $1,055,547 $51,646 

Set (ii) $3,644,525 $110,382 $433,409 $1,325,082 $4,948 $372,024 $1,279,558 $119,122 

Set (iii) $305,234 $9,731 $32,847 $127,181 $96 $46,407 $80,010 $8,958 

Figure 4 juxtaposes the 2002 export data in the subsets of NAICS 331111 with the 

number of employees listed in Table 2. Note a large ratio of exports per employee in set (ii) of 

the product classes. 

 

31 2002 Economic Census 
Manufacturing and Services Economics Brief No. 1 

16 Disaggregated Analysis of Competitiveness and Employment Issues

Figure 4: Iron and Steel Product Classes: Exports and Employees 

5. Modeling Exercises 

The data collected for this paper provides information and/or complementary analysis to 

sophisticated, general-equilibrium analyses of regulation-driven changes in energy costs. 

Computable general equilibrium (CGE) models have illuminated cross-sector variances for 

climate legislation and proposed mitigating strategies, including the Interagency Report’s 

estimation (which is based largely in part on Fischer and Fox (2007)), and Ho, Morganstern and 

Shih (2008)’s estimates, both using variations of the Global Trade Analysis Project (GTAP).32 

These models provide estimates at various levels of sector disaggregation for the effects of 

climate change reduction strategies on multiple variables, including output and production cost. 

 

32 https://www.gtap.agecon.purdue.edu/ 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

$‐

$500,000

$1,000,000

$1,500,000

$2,000,000

$2,500,000

$3,000,000

$3,500,000

$4,000,000

$4,500,000

$5,000,000

2002

Exports

($1,000's)

2002

Employees

2002

Exports

($1,000's)

2002

Employees

2002

Exports

($1,000's)

2002

Employees

Set (i) Set (ii) Set (iii)

Number of Employees

Iron & Steel Product Classes: Exports and Employees

BICSA Non‐Annex I Canada CIS (Russia) Europe ‐ 32 Mexico Other Annex I
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 17 

Ho, Morganstern, and Shih (2008) estimate potential output changes using GTAP’s 

sectors that match 3-digit NAICS sectors for short-run, medium-run, and long-run scenarios, 

defined according to how firms can adjust prices, reallocate capital, or incorporate energyefficient technology. Ho, et al., assume that short run changes in output correspond 

proportionally to employment, and thus, in Table 5 we provide estimates on employment 

changes in relevant EITE sectors. In the long run, the models assume that labor markets adjust 

to offset losses with gains in other sectors. This study simulates the impact of a $10-per-ton 

price of CO2. 

Table 5: Potential employment changes based on H/M/S (2008) estimates

NAICS Sector Employees33 Percent Estimated 

Employment Change34

Corresponding Change in 

Employment Numbers35

 SR MR LR SR MR LR 

311 Food 18,825 -0.38 0.06 0.08 -72 11 15 

313-314 Textile 28,327 -1.13 -0.52 -0.32 -320 -147 -91 

315 Apparel -1.03 -0.1 0.05 

321-322 Lumber,wood, paper 145,173 -0.53 -0.25 -0.1 -769 -363 -145 

324 Petroleum refining -0.78 -5.64 -3.86 

325 Chemicals and plastics 235,194 -1.74 -0.81 -0.47 -4,092 -1,905 -1,105 

327 Nonmetallic mineral 125,938 -1.2 -0.67 -0.42 -1,511 -844 -529 

331 Primary metals 206,174 -1.57 -1.1 -0.69 -3,237 -2,268 -1,423 

336 Transportation equipment -0.33 -0.44 -0.3 

332 Fabricated metals -1.14 -0.32 -0.15 

333 Other machinery -1 -0.05 0.21 

335 Electrical machinery 8,666 -0.72 -0.55 -0.33 -62 -48 -29 

768,297 -10,064 -5,563 -3,306 

 The Interagency Report specifically analyzed the effects of mitigation strategies 

incorporated into H.R. 2454 (“Waxman-Markey”) on 2-digit EITE sectors. For Iron and Steel, 

the report finds an increase in marginal production costs of two to three percent based on specific 

proposals for H.R. 2454. Computable General Equilibrium simulations conducted for the report 

 

33 2007 Economic Census 

34 Ho, Morganstern, and Stern (2008) 

35 Author’s calculations 
Manufacturing and Services Economics Brief No. 1 

18 Disaggregated Analysis of Competitiveness and Employment Issues

indicate that these cost increases could be eliminated through strategies such as output-based 

allocations and allocations to local energy providers. 

6. Suggested Future Work 

 

The volumes and export shares presented in this paper provide direction for companion 

analysis of the impact of increased energy-input costs on U.S. domestic competitiveness and 

employment, as well as potential effects on overall carbon emissions through various inputs and 

energy intensity of the different sectors. Data from the Bureau of Labor Statistics for the listed 

6-digt NAICS sectors and disaggregated 4-digit HTS sectors could indicate vulnerabilities of 

domestic industries, and EPA data on emissions could provide further light on leakage and CO2 

reduction. 

Existing economic analysis suggests small effects on employment following simulations 

of increased energy-input prices resulting from domestic carbon emission reduction strategies. 

This paper presents disaggregated data in the Iron and Steel sector that might prove valuable for 

incorporation in multi-sector computable general equilibrium models. Such analysis could 

provide further insight into expected competitiveness shifts within the domestic steel sector 

resulting from higher energy-input costs in the United States. 

 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 19 

References 

Becker, Randy A. and Wayne B. Gray. May 2009. NBER-CES Manufacturing Industry 

Database, accessed February 17, 2010, at http://www.nber.org/data/nbprod2005.html. 

Bleischwitz, Raimund, Katrin Fuhrmann, and Elias Huchler. September 2007. The 

Sustainability Impact of the EU Emissions Trading System on the European Industry. 

Bruges European Economic Policy Briefings No. 17. 

Carbon Trust. 2004. The European Emissions Trading Scheme – Implications for Industrial 

Competitiveness, London. 

U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Industrial 

Technologies Program. September 2005. Steel Industry Marginal Opportunity Study. 

Analysis prepared by Energetics, Inc., pages 3 and 7. 

 “The Effects of H.R. 2454 on International Competitiveness and Emission Leakage in EnergyIntensive Trade-Exposed Industries,” An Interagency Report Responding to a Request from 

Senators Bayh, Specter, Stabenow, McCaskill, and Brown, December 2, 2009. 

http://epa.gov/climatechange/economics/pdfs/InteragencyReport_Competitiveness-EmissionLeakage.pdf

Fischer, Carolyn and Alan Fox. 2007. Output-Based Allocation of Emissions Permits for 

Mitigating Tax and Trade Interaction. Land Economics 83: 575-599. 

Fischer, Carolyn and Richard Morganstern. November 2009. “Designing Provisions to 

Maintain Domestic Competitiveness and Mitigate Emissions Leakage.” Designing a Capand-Trade System for the United States: Issues, Challenges, and Tradeoffs, Bryan K. 

Mignon, ed. Washington, DC: Energy Security Initiative at Brookings, 2009. 

Ho, Mun S., Richard Morganstern, and Jhih-Shyang Shih. 2008. “Impact of Carbon Price 

Policies on U.S. Industry.” Discussion Paper 08-37, Washington, DC: Resources for the 

Future. 

Hufbauer, Gary Clyde, Steve Charnovitz, and Jisun Kim. 2009. Global Warming and the World 

Trading System, Peterson Institute for International Economics. 

McKinsey and ECOFYS. 2006. EU ETS Review: Report on International Competitiveness, 

European Directorate General for Environment, Brussels. 

Pierce, Justin R. and Peter K. Schott. November 2009. A Concordance Between Ten-Digit U.S. 

Harmonized System Codes and SIC/NAICS Product Classes and Industries. Mimeo, Yale 

University. 

Stavins, Robert N. and Scott Barrett. 2002. Increasing Participation and Compliance in 

International Climate Change Agreements. Working Paper No. RWP02-031, Kennedy 

School of Government, Harvard University. 

Yudken, Joel S. and Andrea M. Bassi. 2009. Climate Policy and Energy-Intensive 

Manufacturing: Impacts and Options. High Roads Strategies and Millennium Institute. 

 
Manufacturing and Services Economics Brief No. 1 

20 Disaggregated Analysis of Competitiveness and Employment Issues

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International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 21 

Appendix 

Table A-1: Ranking Employees with Trade (in $1,000’s) 

(Employees from 2007 Economic Census; Total Trade in 2008 dollars from USITC DataWeb) 

NAICS Description Employees Total Trade NAICS Description Employees Total Trade 

331111 Iron & steel mills 114,315 $57,000,655 325131 Inorganic dye & 

pigment mfg 

7,606 $3,076,660 

325211 Plastics material & resin 

mfg 

71,216 $38,380,722 212234 Copper & Nickel Ores 7,288 $1,780,295 

325199 All other basic organic 

chemical mfg 

70,602 $57,151,293 322110 Pulp mills 7,268 $8,772,304 

331511 Iron foundries 51,503 $2,076,992 327992 Ground or treated 

mineral & earth mfg 

6,497 $583,469 

322130 Paperboard mills 36,641 $240,057 325181 Alkalies & chlorine 

mfg 

6,364 $2,694,000 

325188 All other basic inorganic 

chemical mfg 

35,801 $21,660,701 327122 Ceramic wall & floor 

tile mfg 

6,272 $1,421,889 

313111 Yarn spinning mills 24,750 $1,904,796 327125 Nonclay refractory 

mfg 

5,338 $874,709 

327212 Other pressed & blown 

glass & glassware mfg 

21,189 $3,719,614 212210 Iron Ores 5,189 $2,161,689 

321219 Reconstituted wood product 

mfg 

20,426 $2,074,822 322122 Newsprint mills 4,917 $6,105,744 

327993 Mineral wool mfg 18,891 $1,317,963 327111 Vitreous china plumbing 

fixture & bathroom 

accessories mfg

4,825 $951,918 

327310 Cement mfg 17,749 $896,213 327113 Porcelain electrical 

supply mfg 

4,465 $453,788 

331210 Iron & steel pipe & tube 

mfg from purchased steel 

17,408 $2,417,663 327410 Lime mfg 4,369 $62,597 

327213 Glass container mfg 14,928 $1,231,906 325311 Nitrogenous fertilizer 

mfg 

3,920 $8,710,649 

325222 Noncellulosic organic fiber 

mfg 

14,684 $3,543,850 314992 Tire cord & tire fabric 

mills 

3,577 $543,086 

327211 Flat glass mfg 10,991 $2,083,098 325192 Cyclic crude & 

intermediate mfg 

3,006 $12,954,590 

325212 Synthetic rubber mfg 9,794 $6,152,277 331112 Electrometallurgical 

ferroalloy product mfg 

2,144 $5,596,031 

311613 Rendering & meat 

byproduct processing 

9,355 $1,314,954 331411 Primary smelting & 

refining of copper 

1,771 $6,922,532 

331312 Primary aluminum 

production 

9,355 $8,849,269 327123 Other structural clay 

product mfg 

1,650 $54,113 

325110 Petrochemical mfg 9,257 $17,457,699 331311 Alumina refining 1,611 $1,580,656 

327112 Vitreous china, fine 

earthenware, & other 

pottery product mfg 

8,774 $2,485,032 325182 Carbon black mfg 1,591 $501,605 

335991 Carbon and Graphit Mfg 8,666 $3,962,339 325221 Cellulosic organic 

fiber mfg 

1,353 $1,251,511 

311221 Wet corn milling 8,448 $3,079,391 311213 Malt mfg 1,022 $475,031 

331419 Other nonferrous metal 

primary smelting & refining 

8,067 $44,098,655 Total 780,774 $364,062,477 

 
Manufacturing and Services Economics Brief No. 1 

22 Disaggregated Analysis of Competitiveness and Employment Issues

Table A-2: BICSA and Non-Annex I Share of U.S. Exports 

 BICSA Share BICSA share 

NAICS Total U.S. 

Exports 

Total NonAnnex I

NAICS Total U.S. 

Exports 

Total NonAnnex I

Minerals and Ores $3,023,186 17% 88% Nonmetallic Mineral Products $5,540,581 10% 30% 

212210 Iron Ores $1,244,235 1% 29% 327111 China Plumbing, 

Earthenware Bathroom $109,704 6% 20% 

212234 Copper & Nickel 

Ores $1,778,951 29% 91% 327112 China, Fine Earthenware $597,245 5% 22% 

Food and Kindred Products $3,608,642 3% 6% 327113 Porcelain Electrical $152,303 3% 10% 

311213 Malts $258,106 3% 17% 327122 Ceramic Wall & Floor 

Tiles $43,513 1% 6% 

311221 Wet Corn Milling $2,286,171 2% 5% 327123 Other Structural Ceramic $17,114 3% 4% 

311613 Animal Fats, Oils $1,064,365 4% 8% 327125 Nonclay Refractory $451,756 10% 33% 

Textiles and Fabrics $1,346,669 1% 1% 327211 Drawn, Blown, Float, 

Flat Glass $1,315,136 9% 20% 

313111 Yarns $1,346,669 1% 1% 327212 Other Pressed & Blown 

Glass $1,438,606 14% 40% 

Textile Mill Products $125,650 11% 44% 327213 Glass Containers $262,238 2% 29% 

314992 Tire Cords & Fabrics $125,650 11% 44% 327310 Cements $107,425 1% 4% 

Paper $12,916,113 13% 33% 327410 Lime & Calcinated 

Dolomite $25,754 1% 21% 

322110 Pulp Mill Products $4,839,955 18% 49% 327992 Ground or Treated 

Mineral, Earth $207,794 12% 31% 

322121 Paper Mill $7,118,134 9% 23% 327993 Mineral Wool & Glass 

Fibers $811,993 14% 43% 

322122 Newsprint Mill $847,377 17% 34% Primary Metal Manufacturing $41,598,809 9% 44% 

322130 Paperboard Mill $110,647 2% 4% 331111 Iron & Steel $16,655,979 11% 39% 

Chemicals $88,032,576 15% 36% 331112 Em Ferroalloy $228,203 7% 70% 

325110 Petrochemicals $1,984,688 6% 20% 331222 Steel Wire Drawing $450,986 9% 39% 

325131 Inorganic Dyes 

and Pigments 

$2,011,522 14% 33% 331311 Alumina Refining $612,250 9% 52% 

325181 Alkalies and 

Chlorine 

$2,046,287 19% 30% 331312 Prim. Aluminum $996,149 2% 31% 

325182 Carbon Black $304,888 22% 61% 331411 Secondary Smelting 

(Aluminum) $640,107 15% 54% 

325188 Other Basic 

Inorganic 

$9,888,601 12% 31% 331419 Other Aluminum 

Rolling, Drawing $20,993,531 7% 50% 

325192 Cyclic Crude & 

Intmdtes 

$5,368,450 18% 46% 331511 Iron Foundries $1,021,604 21% 48% 

325199 Other Basic 

Organic Chem 

$32,507,288 13% 33% Electrical Equipment $1,133,353 15% 48% 

325211 Plastic Materials, 

Resins 

$27,469,958 16% 37% 335991 Carbon and Graphite 

Product Manufacturing $1,133,353 15% 48% 

325212 Synthetic Rubbers $4,110,402 22% 52% Total $157,325,579 12% 36% 

325221 Cellulosic Organic 

Fibers 

$957,290 33% 48% 

325222 Noncellulosic 

Organic 

$1,383,202 12% 38% 

 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 23 

Table A-3: Rank of 4-digit HTS Iron and Steel by exports to BICSA countries (in $1,000’s) 

(2008 data collected from USITC dataweb) 

HTS HTS Definition BICSA NonAnnex I

HTS HTS Definition BICSA NonAnnex I

7304 tubes, pipes and hollow 

profiles, seamless, of iron 

$554,285 60% 2704 coke and semicoke of coal, of 

lignite or of peat 

$13,686 8% 

7225 flat-rolled alloy steel (other 

than stainless) pro 

$410,323 39% 7212 flat-rolled iron or nonalloy 

steel products, less 

$10,210 9% 

7208 flat-rolled iron or nonalloy 

steel products, 600 M 

$224,637 18% 7305 tubes and pipes nesoi (welded 

etc.), having intern 

$9,660 13% 

7220 flat-rolled stainless steel 

products, less than 60 

$112,488 45% 7214 bars and rods of iron or 

nonalloy steel nesoi, not 

$6,589 11% 

7302 railway or tramway track 

construction material of 

$66,455 39% 7301 sheet piling of iron or steel, 

whether or not dril 

$6,315 52% 

7306 tubes, pipes and hollow 

profiles nesoi (open seame 

$65,056 22% 7209 flat-rolled iron or nonalloy 

steel products, 600 M 

$6,223 7% 

7210 flat-rolled iron or nonalloy 

steel products, 600 M 

$62,567 17% 7221 bars and rods of stainless steel, 

hot-rolled, in i 

$4,732 40% 

7228 bars and rods nesoi, angles, 

shapes and sections o 

$56,529 20% 7215 bars and rods of iron or 

nonalloy steel nesoi, not 

$4,593 25% 

7205 granules and powders, of pig 

iron, spiegeleisen, i 

$43,873 44% 7211 flat-rolled iron or nonalloy 

steel products, less 

$4,592 5% 

7219 flat-rolled stainless steel 

products, 600 MM (23.6) 

$36,814 11% 2619 slag, dross (other than 

granulated slag), scalings 

$4,315 52% 

7226 flat-rolled alloy steel (other 

than stainless) pro 

$34,406 25% 7227 bars and rods of alloy steel 

(other than stainless 

$3,164 28% 

7216 angles, shapes and sections of 

iron or nonalloy st 

$29,545 14% 7213 bars and rods of iron or 

nonalloy steel, hot-rolle 

$2,505 26% 

7206 iron and nonalloy steel ingots 

or other primary 

$25,652 62% 2618 granulated slag (slag sand) 

from iron or steel man 

$908 43% 

7217 wire of iron or nonalloy steel $24,769 22% 3103 mineral or chemical fertilizers, 

phosphatic 

$460 64% 

7222 bars and rods of stainless steel 

nesoi; angles, sh 

$22,059 26% 2706 mineral tars, including 

reconstituted tars 

$249 34% 

7224 alloy steel (other than 

stainless) in ingots, othe 

$20,413 30% 7201 pig iron and spiegeleisen in 

pigs, blocks or other 

$215 7% 

7218 stainless steel ingots, other 

primary forms and 

$17,412 36% 2705 coal gas, water gas, producer 

gas and similar gase 

$5 57% 

7207 semifinished products of iron 

or nonalloy steel 

$15,392 70% 

 
Manufacturing and Services Economics Brief No. 1 

24 Disaggregated Analysis of Competitiveness and Employment Issues

Table A-4: U.S. Census Definitions of 7-digit NAICS 

3311111 Iron and Steel Mills - Fully Integrated. 

Establishments primarily engaged in smelting iron ore in a blast furnace to produce pig iron in molten or 

solid form; then converting pig iron into steel by removal of the carbon in the iron through combustion in a 

basic oxygen or electric furnace; then producing iron and steel basic shapes, such as plates, sheets, strips, 

and bars, and other related products, such as pipes, tubes, and wire. 

3311112 Iron and Steel Mills - Partially Integrated With a Blast Furnace. 

Establishments primarily engaged in smelting iron ore in a blast furnace to produce pig iron in molten or 

solid form; then converting pig iron into steel by removal of the carbon in the iron through combustion in a 

basic oxygen or electric furnace; then producing ingots and/or semifinished shapes, such as blooms, billets, 

and rods. 

3311113 Iron and Steel Mills - Partially Integrated Without a Blast Furnace. 

Establishments primarily engaged in converting pig iron, direct reduced iron, and/or scrap into steel by 

removal of the carbon in the iron through combustion in a basic oxygen or electric furnace; then producing 

iron and steel basic shapes, such as plates, sheets, strips, and bars, and other related products, such as pipes, 

tubes, and wire. 

3311114 Iron and Steel Mills - Nonintegrated. 

Establishments primarily engaged in producing iron and steel basic shapes, such as plates, sheets, strips, 

and bars, and other related products, such as pipes, tubes, and wire from purchased ingots and/or 

semifinished shapes, such as blooms, billets, and rods. 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 25 

Figure F-1: U.S. Export/Import Shares by 3-digit NAICS codes for EITE industries 

 

5% 25% 25%

23%

21% 11%

16% 18% 9% 10%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

212 322 325 327 331

Minerals &

Ores

Pulp & Paper Chemicals Nonmetallic

Minerals

Primary

Metal Mfg

$1,355,763 $11,183,819 $71,708,344 $4,889,760 $31,292,515

U.S. Export Share by 3‐digit NAICS  (2009)

BICSA

Other Non‐Annex I

CIS (Russia)

Other Annex I

Mexico

Canada

Europe ‐ 32

5%

4%

25%

9%

20%

4% 10% 12%

34%

16%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

212 322 325 327 331

Minerals &

Ores

Pulp & Paper Chemicals Nonmetallic

Minerals

Primary

Metal Mfg

$375,422 $11,259,693 $54,122,147 $7,985,868 $46,874,455

U.S. Import Share by 3‐digit NAICS  (2009)

BICSA

Other Non‐Annex I

CIS (Russia)

Other Annex I

Mexico

Canada

Europe ‐ 32
Manufacturing and Services Economics Brief No. 1 

26 Disaggregated Analysis of Competitiveness and Employment Issues

Figure F-2: 4-digit NAICS trade exposure by region 

 

$10,751

$6,745

$0

$10,000

$20,000

$30,000

$40,000

$50,000

212231123116313131493212322132513252325332713272327332743279331133123313331433153359

23% 4% 2% 2% 5% 1% 16% 15% 21% 12% 7% 10% 0% 1% 10% 11% 7% 7% 10% 21% 8%

2009 U.S. Exports by 4‐digit sector ($ millions)

Europe ‐ 32 Canada Mexico Other Annex I CIS (Russia) Other Non‐Annex I BICSA

$10,572

$5,724

$0

$10,000

$20,000

$30,000

$40,000

$50,000

212231123116313131493212322132513252325332713272327332743279331133123313331433153359

4% 3% 21% 13% 25% 17% 10% 14% 9% 2% 44% 29% 7% 0% 26% 22% 33% 7% 10% 52% 33%

2009 U.S. Imports by 4‐digit sector ($ millions)

Europe ‐ 32 Canada Mexico Other Annex I CIS (Russia) Other Non‐Annex I BICSA

Pulp, Paper, and 

Paperboard Mills 

Basic Chemicals 

Resin, Synth Rubber 

Iron, Steel, 

Ferroalloy 

Nonferrous 

Metal 

Electrical 

Equipment 
International Trade Administration 

Disaggregated Analysis of Competitiveness and Employment Issues 27 

Figure F-3: 6-digit NAICS 3251 Basic Chemicals and 3252 (Resin, Synthetic Rubber, etc) 

Figure F-4: 6-digit NAICS for 3221, 3311, and 3314 

 

$8,478

$7,248

$4,133

$4,319

$0

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$35,000

Petrochemicals Inorganic Dyes

and Pigments

Alkalies and

Chlorine

Carbon Black Other Basic

Inorganic

Cyclic Crude &

Intmdtes

Other Basic

Organic Chem

Plastic Materials,

Resins

Synthetic

Rubbers

Cellulosic

Organic Fibers

Noncellulosic

Organic

325110 325131 325181 325182 325188 325192 325199 325211 325212 325221 325222

6% 14% 19% 22% 12% 18% 13% 16% 22% 33% 12%

6-digit NAICS Exports for 3251, 3252 ($ millions)

$2,095

$2,757

$1,497

$1,797

$1,507

$0

$5,000

$10,000

$15,000

$20,000

$25,000

Pulp Mill

Products

Paper Mill Newsprint

Mill

Paperboard

Mill

Iron & Steel Em

Ferroalloy

Steel Wire

Drawing

Alumina

Refining

Prim.

Aluminum

Secondary

Smelting

(Aluminum)

Other

Aluminum

Rolling,

Drawing

322110 322121 322122 322130 331111 331112 331222 331311 331312 331411 331419

18% 9% 17% 2% 11% 7% 9% 9% 2% 15% 7%

6-digit NAICS Exports 3221, 3311, 3314 ($ millions)
About the Office of 

Competition and Economic Analysis 

The Office of Competition and Economic Analysis (OCEA), a part of the 

International Trade Administration’s Manufacturing and Services unit, provides 

industry and policy decision makers with information on the impacts of economic 

and regulatory policies on U.S. manufacturing and services industries. Its staff of 

specialists perform in-depth industry analysis on the effects of both domestic and 

foreign policy developments on U.S. business competitiveness. For more 

information, or to access other OCEA reports, visit www.trade.gov/mas/ian, or 

contact the office at (202) 482-5145. 

The International Trade Administration's mission is to create prosperity by strengthening 

the competitiveness of U.S. industry, promoting trade and investment, and ensuring fair 

trade and compliance with trade laws and agreements.