USA Arthur Huxham USA Arthur Huxham

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.

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Anna Larsson Anna Larsson

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.

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IMO Arthur Huxham IMO Arthur Huxham

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.

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IMO Anna Larsson IMO Anna Larsson

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.

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