WSC comments to the USTR Request for Comments on Proposed Actions in the Section 301 Investigation
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.
Proposal for a clarification to the draft Revised Recommendations for entering enclosed spaces aboard ships
This document proposes a necessary clarification of paragraph 3.2 of the draft Revised Recommendations for entering enclosed spaces aboard ships, before adoption by MSC 110, in order to ensure its alignment with SOLAS and relevant mandatory Codes.
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.
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.