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U.S. Trade Representative Seeks Public Comment on Reciprocal Tariffs
by: Linda M. Weinberg, Nicholas A. Galbraith of Barnes & Thornburg LLP  BT International Trade Alert
Monday, February 24, 2025

In an as-yet unpublished Federal Register notice, the Office of the U.S. Trade Representative (USTR) has issued a Request for Comments to Assist in Reviewing and Identifying Unfair Trade Practices and Initiating All Necessary Actions to Investigate Harm from Non-Reciprocal Trade Arrangements. Comments must be filed by March 11, 2025.

President Donald Trump issued a Presidential Memorandum on Reciprocal Trade and Tariffs that directs the U.S. Department of Commerce and the USTR, in consultation with other agencies, to investigate the harm to the U.S. from such non-reciprocal trade practices by trading partners beginning after April 1.

In its request for comments, the USTR indicates that it is pursuing a review of all countries but is “particularly interested” in the unfair or non-reciprocal practices of the largest trading economies and those with the largest trade deficits in goods with the U.S. USTR specifically called out Argentina, Australia, Brazil, Canada, China, the European Union, India, Indonesia, Japan, Korea, Malaysia, Mexico, Russia, Saudi Arabia, South Africa, Switzerland, Taiwan, Thailand, Türkiye, United Kingdom, and Vietnam.

The USTR is requesting that commenting parties quantify in dollars the harm or cost – in actual cost or opportunities – to U.S. “workers, manufacturers, farmers, ranchers, entrepreneurs and businesses” as a result of the trade practices that are the subject of the comments. Moreover, comments should be filed on a country-by-country basis.

USTR is particularly interested in submissions related to the largest trading economies, such as G20 countries, as well as those economies that have the largest trade deficits in goods with the United States, including Argentina, Australia, Brazil, Canada, China, the European Union, India, Indonesia, Japan, Korea, Malaysia, Mexico, Russia, Saudi Arabia, South Africa, Switzerland, Taiwan, Thailand, Türkiye, United Kingdom, and Vietnam. These countries cover 88 percent of total goods trade with the United States.
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