NBAA Tells Commerce Dept.: Free, Fair Trade Critical to Aviation; Members Urged to Weigh in by June 3 Deadline
/In comments submitted in response to a Department of Commerce Section 232 investigation into the impact of tariffs on aviation, the National Business Aviation Association (NBAA) emphasized the critical need to maintain the duty-free treatment of civil aviation goods, as established under the 1979 Agreement on Trade in Civil Aircraft.
“It has been many decades since the United States led the development, negotiation and implementation of the 33 country Agreement on Trade in Civil Aircraft,” NBAA wrote in comments submitted to the public docket June 2. “Since the full implementation of the Agreement on Trade in Civil Aircraft in 1980, the United States has dominated every aspect of civil aviation and enjoyed a massive trade surplus. It is compelling proof that President Trump is right – when trade policies are free, fair and reciprocal the United States wins big.”
In 2024, the U.S. civil aviation industry recorded a net positive trade balance of $104 billion, with $124 billion in exports and $20 billion in imports. As the nation’s second-largest manufacturing export sector, civil aviation has consistently held the highest trade surplus among all manufacturing sectors for decades. The industry supports 9.4 million jobs, generates $1.8 trillion in total economic output, and accounts for 4% of U.S. gross
Read NBAA’s full comments to the Department of Commerce.
The association encourages its members and other business aviation stakeholders to weigh in on the Commerce Department’s investigation. The May 28 ruling from the U.S. Court of International Trade, blocking the president’s tariffs imposed under the International Emergency Powers Act – such as the “Liberation Day” tariffs and the 25% tariffs on Canada and Mexico – does not impact the Section 232 investigation.
The deadline for comments is June 3, 2025.
Stakeholders are urged to use NBAA’s online Grassroots Action Center resource to submit comments, data, analyses or other information to the Commerce Department, and the agency will acknowledge significant industry participation.
The most effective comments will share personal or company experiences regarding the impact or anticipated impact of tariffs. All comments will be publicly available unless submitted as “business confidential.”
Following the comment period, the commerce secretary will submit a report on the investigation findings and recommendations to the president. While Section 232 investigations under the Trump administration have resulted in the imposition of tariffs, the president may take non-trade related actions as well.