Article By: Rick Walker, Vice President, TradeInsights, LCB/CCS

Pursuant to the America First Trade Policy Presidential Memorandum and the Presidential Memorandum on Reciprocal Trade and Tariffs, the USTR invites comments from the public, on a country-by-country basis, to assist the U.S. Trade Representative in reviewing and identifying any unfair trade practices by other countries, and in initiating all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements. This information will assist the U.S. Trade Representative in recommending appropriate actions to remedy such practices and reporting to the President proposed remedies in pursuit of reciprocal trade relations.

The USTR invites any interested party to provide information relating to any unfair trade practice by a foreign country or economy or with respect to a non-reciprocal trade arrangement. Unfair trade practices may encompass an expansive range of practices, such as policies, measures, or barriers that undermine or harm U.S. production, or exports, or a failure by a country to take action to address a non-market policy or practice in a way which harms the United States. The information should include the foreign country or economy concerned, the practice or trade arrangement of concern, a brief explanation of the operation of the practice or trade arrangement, and an explanation of the impact or effect of the practice or trade arrangement on the interested party or on U.S. interests generally. Submissions should quantify the harm or cost (including actual cost or opportunity cost) to American workers, manufacturers, farmers, ranchers, entrepreneurs and businesses from the practice or trade arrangement of concern—ideally ascribing a dollar amount to the harm or cost and describing the underlying methodology.

The notice, found here, defines unfair trade practices as “policies, measures, or barriers that undermine or harm U.S. production, or exports, or a failure by a country to take action to address a non-market policy or practice in a way which harms the United States.” Submissions should include the foreign country or economy concerned, details of the trade arrangement, and an explanation of how the arrangement impacts the United States. While the USTR is accepting comments on all countries, particular attention will be given to major US trading partners and nations with which the US has a significant trade deficit.

The deadline to comment is March 11, 2025. Comments can be submitted here: http://www.regulations.gov/commenton/USTR_FRDOC_0001-0878.

We will continue to monitor this action and provide updates when available.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions.