AFS is the only association working full-time to advocate for a positive business climate for the $50 billion metalcasting economy.
Federal Priority Issues By Year
About AFS Policy Priorities
AFS 2025-2026 Draft Public Policy Agenda
The strength and vitality of the U.S. economy requires a strong, innovative and enduring domestic metalcasting industry. The nation’s 1,7000 metalcasters design, manufacture and finish highly engineered metal castings that are essential to how the modern world functions. Castings are found in motor vehicles, rolling stock, aerospace, national defense, agriculture, energy development, mining, medical devices, water systems, fire safety and dozens of other vital applications.
Metalcasting has annual U.S. sales of $50 billion, an economic impact of $110.5 billion, and accounts for 490,000 jobs either directly, indirectly or through induced (related) impacts. State-by-state and District-by-District impacts can be found in the Economic Impact Analysis
The American Foundry Society (AFS), North America’s largest metalcasting trade association and professional society, advocates proactively for the metalcasting economy, thanks to the investment of our Corporate Members, throughout the year. Now is the time for the Administration and Congress to adopt high-impact policies to bolster manufacturing and metalcasting in America. AFS presents the following AFS Public Policy Agenda and will work to advance this agenda throughout 2025-2026.
Permitting Reform
AFS supports public policy improvements at the federal and state levels to streamline the process of issuing permits for the design, construction and launch of much-needed energy, transportation-infrastructure and construction projects.
Infrastructure projects can be completed in an environmentally sound manner without the endless litigation and administrative red tape that characterize the current system.
The U.S. is in intense competition with other nations for manufacturing competitiveness. The current permitting process constitutes a drag on U.S. productivity and detracts from the vital goal of making the U.S. the best place in the world to manufacture and transport world-class products.
International Trade
AFS supports a fair playing field for manufacturers to participate in global trade, including vigorous enforcement of U.S. trade laws and international trade agreements. Illicit foreign trade practices have contributed to the closure of some casting-consuming factories and metal foundries, leading to job losses for American families in many U.S. communities. These illicit practices must come to an immediate end. Therefore:
China Trade. China was admitted into the World Trade Organization on December 11, 2001. Since then, China has regularly and methodically engaged in unfair and unlawful trade practices, such as currency manipulation, intellectual property theft, subsidies, and dumping, which result in an uneven playing field, and a shift of market share away from the U.S. AFS supports federal policies that impose reciprocity upon China – and that provides enhanced remedies for U.S. companies that are harmed by China’s unfair trade practices.
Tariffs. The judicious use of tariffs can help achieve a more level playing field in international trade. AFS supports retention and expansion of the Section 232 and 301 tariffs on ferrous and non-ferrous metal casting imports adopted during the first Trump Administration. In addition, broad-based tariffs may be added to provide protection to jobbing foundries that cannot be included into industry-specific trade legislation or legal actions. Any trade package should include a renewal of the miscellaneous tariff law which exempts from tariffs key products not made in the United States.
Remedies. The Society supports strengthening U.S. antidumping and countervailing duty laws. Congress must ensure adequate resources for the agencies responsible for enforcing these laws. AFS calls for prompt adoption of legislation that strengthens trade remedies, including “Fighting Trade Cheats” and “Leveling the Playing Field 2.0.” Policies should especially crack down on repeat offenders and serial trade cheaters.
Currency Manipulation. AFS supports continuing to allow the countervailing duty law to be applied to currency manipulation by foreign governments.
Trade Enforcement. AFS backs vigorous enforcement of U.S. trade laws. The Administration should work to halt unjustifiable transshipment practices, circumvention, country of origin marking deficiencies and other forms of evasion of trade remedy orders.
Transshipments. While the Sec. 301 and 232 tariffs implemented in 2018 have reduced some direct Chinese exports to the U.S., indirect Chinese exports are finding their way here through other countries. Global container traffic data, compiled by Xeneta, shows China’s container exports to Mexico rose nearly 60% in the 12 months leading up to January 2024. There is a challenge posed by foreign producers collaborating with unscrupulous importers to bypass U.S. duties and dumping laws. U.S. manufacturers bring trade cases against subsidized imports sold below the cost of production, but even when U.S. firms obtain anti-dumping and countervailing duty remedies, importers and producers often evade them through trans-shipment schemes, false documentation, and shell companies to hide import data. AFS urges that the Sec. 232 and Sec. 301 tariffs on castings remain in place; strengthen and aggressively enforce U.S. antidumping and countervailing duty laws; and ensure adequate resources for agencies enforcing trade laws.
Reshoring. AFS encourages voluntary reshoring initiatives for castings and other critical goods. AFS partners with The Reshoring Initiative, which helps companies quantify the financial benefits of reshoring. AFS also advocates public policies that result in shorter, trustworthy supply chains for critical minerals that we can mine and utilize domestically.
Export Promotion. Federal programs that assist manufacturers in the complex process of exporting and complying with export-licensing and similar requirements should be adequately funded.
Pro-Growth Tax Policy
Manufacturing is essential to the standard of living of Americans. The U.S. needs a tax policy that is predictable, globally competitive, and focused on retaining/attracting manufacturing, jobs, investment and innovation. Key pro-manufacturing provisions from the 2017 tax-reform law that are phasing out should be reinstated and be permanently extended. Specifically:
Rates. The 20% pass-through deduction for qualified business income and the 21% corporate income tax rate should be retained.
Expensing. The tax code should permit businesses to immediately deduct the full cost of capital investments and technology (full expensing/100% bonus depreciation). This provision is essential to capital-intensive industries such as metalcasting and the industries that foundries serve.
R&D. The goal of U.S. policy should be to encourage private-sector R&D activity and resulting production to occur here rather than overseas. The R&D tax credit should be permanent in order to offer predictability and should provide for immediate and full expensing of R&D investments.
Estate Tax. Since many foundries are family-owned, they must plan for the estate tax to keep the business operating after the death or retirement of the owner. The death tax should be repealed to permit more small businesses to retain stable family ownership. Absent full repeal, provisions adopted in 2017 should be made permanent. In addition, gift tax valuation discounts for lack of marketability and lack of control should be permanently incorporated into tax reform legislation.
Interest Deductibility. Among the already expired provisions is the 2017 tax reform’s standard for interest deductibility, which dictates how much interest on business loans manufacturers can write off. Tax reform capped companies’ interest deductions at 30% of their earnings before, interest, tax, depreciation and amortization (EBITDA). Since 2022, a more restrictive standard has been in place, based on companies’ earnings before interest and tax (EBIT). This makes it harder for manufacturers to finance job-creating investments in equipment and machinery. Congress should reinstate the EBITDA deduction standard.
AMT. The 2017 tax-reform law also repealed the corporate alternative minimum tax (AMT) and reduced the impact of the individual AMT. These changes have encouraged economic growth and should be retained.
Talent Development
U.S. foundries struggle to attract and retain the entry-level, technical, engineering and other high-skill talent they need – at a time that retirements of Baby Boom employees continue at a rapid pace. According to a 2024 report from Deloitte and the Manufacturing Institute, half of the 3.8 million anticipated manufacturing jobs over the next decade could go unfilled if current labor gaps remain unsolved. AFS offers numerous programs and resources throughout the year to help foundries attract and retain talent. In terms of public policy, while there is no silver bullet, AFS urges policymakers to adopt the following key steps:
Training Programs. AFS supports increased employer involvement in shaping workforce training programs. To meet current and future workforce needs, policies should encourage students to consider career and technical education (CTE) to prepare them for rewarding careers in manufacturing. AFS supports reauthorizing and expanding the Workforce Innovation and Opportunity Act (WIOA), which provides education and training to job seekers and connects workers with employers, as well as expanding Pell Grant eligibility to high-quality, short-term programs. Training programs should be continually evaluated and refined to reflect the needs of an ever-evolving workforce and economy.
Training Incentives. AFS supports expanding tax credits for employers that provide training to employees. All training incentives should be structured to allow employers the optimum flexibility needed for the modern workplace.
Legal Immigration. Legal immigration policies should focus on meeting the workforce needs of the U.S. economy and manufacturing.
Environmental Quality
America’s metalcasters are committed to environmental quality and annually invest tens of millions of dollars to advance that cause by meeting regulatory requirements, and in many cases implementing beyond-compliance practices. U.S. environmental quality has improved markedly over the decades. These positive results are evidence that economic growth and environmental quality are not mutually exclusive. The AFS Environment, Health & Safety (EHS) Division provides a wealth of conferences, webinars and resources to help metalcasters achieve environmental goals and compliance.
AFS has a long history of working with regulators and other stakeholders to foster understanding of environmental challenges and the best way of addressing them. AFS urges that environmental policies be based on sound science, feasibility studies, and rigorous cost-benefit analysis. Metalcasters should be afforded flexibility in how they go about achieving environmental standards given the unique nature of their processes and operations.
Particulate Matter 2.5 Non-Attainment. In 2024, EPA – moving ahead of the review schedule required by statute – finalized regulations further reducing the PM 2.5 standard. This change would put vast portions of the U.S. into non-attainment status, resulting in further delays or bans on plant construction and modernization, and jeopardizing the positive reshoring trends. AFS supports returning to the previous PM 2.5 standard and returning to the review schedule called for by statute.
Stormwater Discharge Controls. AFS members are committed to implementation of best management practices and have cooperated with EPA and other industry groups to identify reasonable and appropriate controls. EPA finalized the 2021 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) that authorizes stormwater discharges associated with industrial activity in areas where EPA is the permitting authority. The final 2021 MSPG incorporates measures AFS has advocated, including reduction of burdensome benchmark monitoring requirements, retention of sector-specific stormwater control measures, and greater flexibility for demonstrating compliance. These changes represent a more cost-effective and sustainable approach to minimizing the impact of stormwater discharges that is protective of human health and the environment.
Recycling. The metalcasting industry has a tremendous record of success in terms of recycling in terms of: 1) scrap metal and other metal-bearing materials as raw materials for the casting process; 2) reuse of materials in-house as part of ongoing manufacturing; 3) beneficial use of industrial by-products such as foundry sand; and 4) reclamation or reuse of secondary materials generated from the manufacturing process that are not returned to the foundry. EPA has a stated goal of increasing the U.S. recycling rate to 50 percent by 2030. AFS has commented to EPA that all of its recycling activities should be included to calculate the overall recycling rates in the U.S. and has agreed to work with EPA in continuing to promote recycling activities in the metalcasting industry.
Iron and Steel Foundry Air Emissions Standards. After eight years of implementing National Emissions Standards for Hazardous Air Pollutants (NESHAP) for iron and steel foundries, EPA was required to conduct a residual risk and technology review to determine if the NESHAP has been effective, and if additional controls were needed to protect human health and the environment. Based on its review in October 2020, EPA concluded that no new emission limits were needed for iron and steel foundries. This conclusion is testament that iron and steel foundries have implemented effective control measures to reduce hazardous air pollutant (HAP) emissions and minimize health and environmental risks. In working closely with EPA officials on the development of this rulemaking, AFS provided critical information regarding facility emissions data, foundry production processes, and the operation of air emission control devices used at foundries. These cooperative efforts demonstrated how iron and steel foundries effectively implemented control measures. In addition, AFS identified for EPA substantial work practices that will continue to advance this environmental success story.
Global Climate. Government officials, industry trade groups, community organizations, and the public are developing strategies on the most realistic approaches to reduce greenhouse gas emissions. Metalcasting is an energy-intensive, trade-exposed industry that could be significantly impacted by proposals to address climate change. AFS is evaluating the technical and policy issues associated with climate change and developing a position on how the metalcasting industry can best address climate change measures in an economically and environmentally sustainable manner.
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Green Foundry Initiative and Case Studies. AFS recognizes that a strong business case can be made for promoting environmental sustainability within foundries. Through the Green Foundry Initiative, AFS gathers information from member companies regarding significant and novel approaches to improve sustainability, reduce energy and resource use, decrease or eliminate waste generation, minimize toxicity, identify beneficial use options for spent materials, and generally reduce their environmental footprint while maintaining production.
The Green Foundry Initiative provides metalcasting operations an opportunity to highlight sustainability efforts in:
Management Systems and Metrics
Air Emissions
Water Use and Discharge
Materials and Resource Conservation
Waste Management and Beneficial Use
Critical Minerals
The U.S. is dangerously reliant on potentially unreliable foreign sources of critical minerals. To address this situation:
AFS supports tariff-free access to imported Mexican and Canadian aluminum, nickel, and copper, and other minerals since increased tariffs would raise manufacturing costs and hurt metals-intensive industries, including metalcasting. Two-thirds of US primary aluminum come from Canada. The U.S. only has only one major nickel mine, while Canada supplies the U.S. with about half of its nickel needs. Mexico is one of the world's largest producers of many minerals, including copper, lead, zinc, gold, silver, an oil. US also relies heavily on imports of manganese from Mexico.
AFS supports permitting reforms to streamline the process of approving new mines for copper and other important materials that can be mined in the U.S. Congress should encourage key minerals mining, processing, end-use manufacturing and recycling that expand the availability of minerals essential to the production of castings, energy supply. Congress should also encourage the growth of a domestic critical minerals recycling industry through statutory and administrative changes and legislation that provides regulatory agencies with set timelines to issue permits. Finally, given the importance of petroleum to the U.S. economy, the government should focus on addressing the recent depletion of much of the Strategic Petroleum Reserve so that the nation will be well equipped in the event of a true emergency.
AFS supports the inclusion of copper, electrical steel, silicone and silicon carbide in the federal critical minerals list. These materials are irreplaceable in energy, technology and national security applications, from electrical equipment, water pipes, and batteries to grid transformers and semiconductors. This list determines whether projects tied to the extraction, processing, and refining of these materials are eligible for certain grant programs, tax credits, loan guarantees or improved permitting processes.
Employment & Safety Policy
Employee health and safety is crucial to a strong and sustainable economy. AFS provides safety-related programming throughout each year that supports member companies as they make substantial investments in safety-related training and technology. AFS regularly engages with OSHA and the Labor Department on key employment and safety issues. AFS encourages policies to promote smart and fair regulatory approaches that conform to the following principles:
Collaborative Approach to Enforcement. New and existing workplace laws and regulations should be technologically attainable, based on current risk assessments, practical, and as cost-effective as possible. Employers should be afforded flexibility to meet standards in the best way possible in light of their unique mix of operations, equipment, and product lines. AFS encourages federal and state authorities to emphasize a collaborative and consultative approach with employers as they make conscientious efforts to safeguard their employees and comply with expansive state and federal requirements.
Heat Stress. OSHA has solicited comments on regulating employee exposure to heat. AFS is advising the agency on the best approaches for protecting the heat-related health and safety of foundry employees. AFS will continue to support members in ensuring preparedness for heat-related issues through a wide range of resources.
OSHA Walkaround Rule. The purpose of an OSHA inspection is to verify that a company is compliant with OSHA regulations. AFS strongly opposes the politically motivated 2024 OSHA rule which allows employees to choose third-party representatives, such as a union with no bargaining rights at the company and/or community activists, to accompany an OSHA safety inspector into workplaces during site inspections. This ill-advised rule will not improve factory safety and should be promptly repealed.
Infrastructure Investment
As national and international supply chain disruptions have made clear, maintaining and modernizing our infrastructure – including our ports, highways, railroads, telecommunications, energy grid, water system and more – is essential to keeping products moving and manufacturers operating. Even with the passage of an infrastructure law under the Biden Administration, the U.S. has under-invested in infrastructure investment for many years, with negative implications for our manufacturing competitiveness and quality of life. Accordingly, AFS supports the following policies:
Increased Investment. AFS supports increased investments to continue to modernize roads, highways, bridges, airports, railroad and transit, schools, and ports, as well as drinking water and wastewater systems.
Streamlined Permitting. The Society supports streamlining and accelerating the federal permitting process, as the current lengthy permitting and environmental review process can add to projects’ time and cost, while deterring the entry of private capital.
Buy-American Provisions. AFS supports the principle that when taxpayer funds are used for infrastructure projects, all of the metal used, including castings, should be made in the U.S.
Water Infrastructure. To modernize our water infrastructure, AFS supports full funding for the EPA state revolving loan funds programs, the Water Infrastructure Finance & Innovation Act and other key drinking and wastewater programs.
Energy, Data Centers and the Electrical Grid. The vast growth of data centers – with their enormous need for electricity – underscores that investments in the electrical grid are needed to support electricity supply availability and stability. McKinsey & Company predicts the power needs of data centers will triple, going from 3-4 percent of total power demand today to 11-12 percent in 2030. Comments submitted by AFS to the Department of Commerce in 2024 outlined the need for an energy policy that leverages all forms of energy – natural gas, nuclear, coal, hydro, geothermal, renewables – to meet the nation’s energy needs.
Freight Car Manufacturing. AFS supports legislation to provide a tax credit for U.S. railcar leasing and manufacturing companies for the cost of replacing existing cars with new fuel-efficient railcars or for modernizing existing railcars.