The United States Trade Representative (“USTR”) is requesting comments by March 11, 2025, on unfair trade practices in other countries. This alert provides a brief overview of USTR’s request, its potential impacts, and next steps. 

The Request: USTR is requesting comments as part of President Trump’s America First Trade Policy. President Trump intends to take action to remedy unfair trade practices from any country with which the United States has a trade deficit. USTR is asking for public input identifying unfair trade practices and their impact. There is a particular interest in large economies with which the United States has trade deficits. USTR will use the comments to make recommendations to President Trump in a report due April 1, 2025. The comment period is not exclusive. USTR may take action in advance of these submissions and has said that it welcomes “ongoing engagement” past the comment period.

Potential Impacts: USTR’s list of countries covers 88 percent of goods trade with the United States. For business facing unfair foreign competition, this is an opportunity to let the administration know about your concerns. Unfair trade practices “may encompass an expansive range of practices,” and USTR is open to considering practices not traditionally considered as trade issues. It is unclear what actions the USTR may take to remedy these practices, but increased tariffs are a likely outcome. It is also unclear when such remedies will be put in place. 

Next Steps: Interested parties may submit comments through the USTR Comments Portal. The Blank Rome team can advise and assist companies who wish to participate in this process.