The World Shipping Council (WSC) is the primary trade association representing the international liner shipping industry, which includes the transportation of vehicles and heavy machinery in specialized vehicle carrier vessels. While WSC appreciates the opportunity to comment on these proposed modifications, WSC urges the USTR to open the full Annex III docket for comment, not just USTR’s proposed modifications put forward in its June 6, 2025, Notice of Proposed Modification of Action in Section 301 Investigation of China's Targeting the Maritime, Logistics, and Shipbuilding Sectors for Dominance. In light of the narrow nature of USTR’s request for comments, WSC focuses its comments below on concerns regarding the proposed modifications in Annex III. However, WSC begins by highlighting briefly why Annex III should be withdrawn in its entirety, and why modifications, though desirable, can only mitigate its harm.

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 supports the goal of building a strong and vibrant U.S. shipbuilding and maritime sector. A strong U.S. maritime sector will have positive ripple effects across the entire maritime industry. However, WSC strongly opposes USTR’s proposed port fees and requirements to export on U.S. flag and U.S.-built vessels.

These proposals would cause significant harm to U.S. consumers and exporters. The requirements for exportation on U.S.-built and U.S.-flag vessels, moreover, could prove impossible to meet. Further, the proposals are disconnected from the goal of Section 301: obtaining the elimination of actionable foreign trade policies and practices. Instead, they appear designed to raise revenue and to generate the renewal of the U.S. shipbuilding industry. This falls outside of the U.S. Trade Representative’s remedial authority.