WSC comments to the USTR Request for Comments on Proposed Actions in the Section 301 Investigation

WSC respectfully submits these comments on the Notice of Action and Proposed Action, Request for Comments, and Notice of Public Hearing issued on April 17, 2025.

WSC’s members operate approximately 90 percent of the world’s liner vessel services. The global liner shipping industry includes over 6,000 ocean-going vessels. Each year, approximately 1,100 liner vessels sail into U.S. ports, making over 18,000 U.S. port calls. Transporting $1.5 trillion in U.S. trade, the liner shipping industry supports over 6.4 million U.S. jobs and contributes over $1.1 trillion to the U.S. Gross Domestic Product. WSC reiterates its support for the Administration’s goal of building a strong and vibrant U.S. shipbuilding and maritime sector. A strong U.S. maritime sector will have positive effects across the entire maritime industry.

However, WSC continues to believe that port fees and export carriage restrictions are not the way to achieve this objective. The fees and export carriage restrictions imposed in Annexes I-IV of the April 17th Notice of Action will increase costs for U.S. consumers and exporters and introduce supply chain inefficiencies, all while failing to incentivize China to alter its acts, policies, and practices.

Without prejudice to WSC’s overall opposition to the fees and export carriage restrictions, and WSC’s position that section 301 does not provide legal authority for the Trade Representative to impose those fees and export carriage restrictions, WSC requests that USTR address certain issues related to Annexes I, II, and III.

Read WSC’s comments on the proposed Action in the Section 301 Investigation here.