Post-Hearing Supplemental Comments of WSC: Concerning Proposed Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance
WSC Comments Concerning Proposed Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance
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.
Testimony of Joe Kramek, President of the World Shipping Council Before the Inter-Agency Section 301 Committee Regarding Docket ID: USTR-2025-0003
WSC Members play crucial roles in the U.S. economy and the U.S. maritime sector. Our members enable American factories and farmers to serve export markets around the globe, supporting countless high-paying jobs across the United States. WSC members operate 75 percent of the U.S. Maritime Administration’s Maritime Security Program Fleet, comprised of U.S. flag, commercially viable, militarily useful merchant ships active in international trade that are available to support U.S. Department of Defense sustainment sealift requirements during times of conflict or other national emergencies. Additionally, WSC members operate two-thirds of the active U.S.-built liner vessels in operation and are responsible for all liner vessels currently on order in U.S. shipyards.
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 the proposals in this proceeding for port fees and for requirements to use U.S.-flagged or U.S.-built vessels. These proposals will result in increased costs for U.S. exporters and consumers as well as supply chain inefficiencies, while failing to provide China with effective incentives to alter its acts, policies, and practices.
Request to Appear Concerning Proposed Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance
The complementary role of regulations and guidelines and the need for core requirements of the GHG agreement to be in regulations
This document examines the critical and complementary role that regulations and guidelines play in the forthcoming GHG instrument. The document also highlights the need to clearly distinguish what are binding regulatory requirements from what the Committee develops as supporting guidelines that provide recommendations concerning more detailed procedures, technical considerations, and other matters important for the implementation of the regulations.
Proposal for an IMO sustainable fuels certification framework in the context of the IMO LCA Guidelines and the IMO net-zero framework (ISWG-GHG 18/2/17)
This document provides an updated proposal on the development of an IMO sustainable fuels certification framework that will allow certification schemes/standards to operate under the purview of the IMO LCA Guidelines, especially with respect to the implementation of the technical and economic elements under the IMO net-zero framework.
Development of Amendments to the revised Guidelines for the Prevention and Suppression of the Smuggling of Drugs (Resolution FAL.9(34) and MSC.228(82))
WSC response to the European Commission's Public Consultation on "Ship recycling – European list of ship recycling facilities (14th edition)
WSC comments post MEPC 82
There has been clear progress in negotiations at MEPC 82, and we are encouraged to see that the key industry priorities of a feebate and closing the price gap between green fuels and fossil fuels are considered critical going forward. Member states recognize that the core purpose of the mid-term measures is to drive the energy transition in the fleet, but there is much work remaining to get there.
Proposal for a sustainable fuels certification framework in the context of the IMO LCA Guidelines and the development of the mid-term measures (ISWG-GHG 17/3/1)
This document provides a concrete proposal on how to address the development of specific certification elements that will enable certification schemes to operate under the purview of the IMO LCA Guidelines, especially with respect to the implementation of the technical and economic elements under the IMO net-zero framework. For this, it is important to include a definition of "certification" in existing regulations and guidelines, and to develop a new set of guidelines and regulations as appropriate, outlining criteria and procedures for recognizing certification schemes and on the reporting of certification activities. The co-sponsors also propose a tentative timeline for this work and invite further proposals addressing the necessary technical and scientific issues and providing guidance on how to develop its contents.
Further development and explanation of the Green Balance Mechanism including draft amendments to MARPOL Annex VI (ISWG-GHG 17/2/1)
Development of measures to prevent the loss of containers at sea (CCC 10/11/5)
This document proposes improvements to be considered for the safe transport, stowage and securing of containers based on preliminary results of the TopTier project.
WSC-BAM charcoal sampling project –progress report on testing the self-ignition behaviour of different charcoal samples
This document informs that WSC and the Bundesanstalt für Materialforschung und -prüfung (BAM) have launched the "charcoal sampling project" through which member carriers of WSC have been sourcing and shipping samples of charcoal (UN 1361) to BAM for laboratory testing. The intention of this project is to inform both carriers and regulators of any increased or decreased risks in the transport of charcoal against the standards that are set in the IMDG Code. The annex of this document provides an interim "progress report on testing the self-ignition behaviour of different charcoal samples" which has been issued by BAM.
Estimate of containers lost at sea – 2024 update (CCC 10/11/1)
Since 2011, the World Shipping Council (WSC) has undertaken a survey of its member companies to accurately estimate the number of containers that are lost at sea each year. WSCʹs member companies operate more than 90% of the global containership capacity; thus, a survey of their losses provides a valid basis for a meaningful estimate of the total number of containers lost at sea. The 2024 update adds information from the year 2023 where a total of 221 containers were lost at sea, out of 250 million transported. Of the containers lost, about 33% were recovered. This represents the lowest losses since the start of the survey in 2011 and a significant improvement on the previous lowest-ever loss of 661 containers in 2022.
Development of measures to prevent the loss of containers at sea (CCC 10/11)
Review of current and future work of the Organization to prevent the loss of containers at sea and to mitigate the impacts of such incidents.
WSC USTR comments on Section 301 investigation
The World Shipping Council (WSC), the international trade association representing container and vehicle carriers, today expressed to the U.S. Trade Representative its concern that the proposed imposition of a port fee on Chinese-built vessels would only serve to raise prices for U.S. consumers and harm U.S. export businesses, acting as a new tax on imports and exports.
WSC response to the EU to the European Commission's Public Consultation on "Ship recycling – European list of ship recycling facilities (13th edition)”
World Shipping Council member companies represent over 90% of global liner shipping industry container and vehicle carrier capacity. We are committed to working with the EU Institutions to advancing sustainable and responsible shipping practices worldwide and support EU leadership at the IMO for more ambitious actions and higher standards when it comes to ship recycling.
Security in the Southern Red Sea and Gulf of Aden.
The security situation in the Southern Red Sea and Gulf of Aden is extremely serious with civilian merchant ships being fired upon and the lives of seafarers being put at risk on a daily basis. Seafarers have been killed and seriously injured in these deliberate and targeted attacks. The co-sponsors detail the volume and the impact of attacks faced by civilian seafarers and request a detailed discussion on the issue within an appropriate group with the aims to condemn the attacks on seafarers and ships and to identify how to achieve a long-lasting security situation that can be put in place after the immediate crisis is resolved.
Consideration of a “Green Balance Mechanism” (ISWG-GHG 16/2/4 )
This paper outlines how development of a ‘Green Balance Mechanism’ (GBM) can help deliver the environmental outcomes identified in IMO’s 2023 GHG Strategy while also providing a targeted economic and regulatory means to incentivise and enable the use of net-zero and near-zero fuels and technologies critical to the needed energy transition. The Green Balance Mechanism is designed to work as part of an integrated measure, a levy / GHG Fuel Intensity (GFI) approach, or as a hybrid measure to be considered in the development and discussion of mid-term measures.
Proposal to forward a list of potential risk-prevention-related areas to the CCC Sub-Committee
In order to serve the need for a holistic risk-based approach, and prioritization of risk prevention and mitigation enhancement when developing amendments, this document proposes that the Sub-Committee, taking into account the preliminary work by the co-sponsors, prepare a list of potential risk-prevention-related areas that would fall under the purview of the CCC Sub-Committee, which could be identified throughout the period of working under this output; and forward this list to the CCC Sub-Committee for consideration and taking action, as appropriate.