USCBC Comment on Proposed Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance

The US-China Business Council (USCBC) welcomes the opportunity to submit comments to the Office of the US Trade Representative’s (USTR) Notice of Proposed Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance, as described in Docket No. USTR-2025-0002. We appreciate USTR’s efforts to address concerns about China’s dominance in the shipbuilding sector and its implications for US economic and national security interests.

USCBC represents over 270 American companies engaged in business activities in China, spanning a wide range of industries, including manufacturing, financial services, technology, retail, energy, and agriculture. Our members are deeply interested in ensuring fair market conditions, promoting the competitiveness of American firms and farmers, and strengthening supply chain resiliency.

We further support USTR’s objective of strengthening American shipbuilding capacity; however, USCBC recommends that USTR refrain from implementing port fees because of the resulting substantial increase to shipping costs, causing harm to US consumers and businesses in critical sectors including energy, manufacturing, mining, pharmaceuticals, consumer products, and agriculture. The fees will also disrupt supply chains by diverting ships to larger ports, Canada and Mexico, and other neighboring countries, taking away business from US ports and delaying deliveries to US businesses which would hurt their operations and sales – all of which support American jobs.

USCBC also recommends USTR refrain from mandatory quotas requiring companies to export from the US using US-built ships. Such a requirement would be unachievable due to insufficient domestic shipyard capacity and the limited availability of specialized vessels required by key industries such as chemicals and energy.

USCBC also requests clarity regarding critical definitions—particularly the term “operator” and Hong Kong’s status under these proposed actions—as well as whether vessels would incur multiple port fees for each US port call.

If USTR does decide to implement its proposed actions, USCBC recommends that USTR narrowly tailor port fees, allow for industry-wide exemptions, phase its implementation timelines, and build strategic international shipbuilding partnerships with US allies.