RILA’s 301 China Shipbuilding Country Of Origin Test Comment

Given these complexities and the precedent this action could set, we urge USTR to reconsider the country-of-origin test included in Annex V for ship-to-shore cranes. If USTR intends to go down this path of expanding origin determination to include Chinese nationals for future actions or negotiations, which we strongly urge against, it is imperative that it consult extensively with stakeholders to ensure it understands the full implications of such a drastic change. It is also imperative that USTR provide ample time for transitioning to these rules, as well as clear guidance as to how varying customs rules will interact so that importers can meet their compliance obligations.