SAFE Experts Comment on Section 301 Tariff Review

Responding to the Biden administration’s trade policy decisions impacting $18 billion worth of goods, conducted as part of the statutorily required 4-year review of Section 301 Tariffs, SAFE’s experts provided the following comments:

Avery Ash, Executive Director of SAFE’s Coalition for Reimagined Mobility:

“Connected, automated and electric technologies will define the next 100 years of success in the automotive sector. We support taking aggressive proactive measures to help maintain leadership in global auto manufacturing for the U.S. and our allies, but these measures must help drive innovation and not unintentionally undercut competitiveness in the process.

China—through two decades of strategic investment, trade practices, and formal and informal subsidies—has successfully positioned their automotive industry for global dominance, coupled with deliberate industrial overcapacity.

The U.S. needs a comprehensive and coordinated response, and tariffs are a powerful but blunt instrument in a complex situation. Addressing China’s unfair trade practices and market manipulation is essential defense, but must be coupled with effective offense—in this case a clear national commitment to and strategy for the U.S. to double-down on the development and deployment of market-defining technologies in the automotive sector. We’ve made early progress to this end in recent years, but much more is needed.

The end goal should be a global market where companies compete transparently on the strength of their standards and innovations and SAFE supports efforts to ensure a level playing field and the competitive success of U.S. and allied automakers.”

ReMo recently submitted detailed comments to the Department of Commerce on the national security implications of connected vehicles with foreign components.

Abigail Hunter, Executive Director of SAFE’s Center for Critical Minerals Strategy:

“Trade policies for mineral supply chains are ideally measured, incremental, and comprehensive—making hard decisions with long-term resiliency in mind. To this end, SAFE lauds the administration’s targeted and sometimes phased-in approach to enable ex-China producers time to build necessary capacity—with a two-year delay on tariffs on natural graphite emerging as an example of a thoughtful timeline that syncs with other policies and long-term goals.

As we await more details, it is worth emphasizing that unilateral tariffs will not address China’s strategic industrial overcapacity, which impacts global markets and U.S. companies. Common border tariffs through a multilateral coordination with allies will be necessary to prevent dumping, and to block Chinese exports from causing global price collapses. While challenging, such efforts are worth advancing in light of the devastating global impacts of China’s work to corner the market from minerals to EVs.

There are other structural issues—energy costs, higher labor costs, permitting reform needs, etc.—undermining the competitiveness of domestic producers along the minerals supply chain. If the goal is to support U.S. industry, tariffs alone will always fall short.”

Hunter recently testified at the International Trade Commission on this specific topic. Her full testimony can be viewed here. SAFE’s Minerals Center is holding a half-day roundtable on trade policy with key stakeholders and policy experts on May 14, and will be sharing a new trade research report from that discussion.

About SAFE’s Coalition for Reimagined Mobility (ReMo)
The Coalition for Reimagined Mobility (ReMo) is a global initiative of SAFE, advancing outcomes to shape transportation systems that are better for people and planet. ReMo convenes private and public sector stakeholders, conducts research, and develops policy for the U.S. and Europe to accelerate the deployment and scaling of transportation technologies that advance efficient, sustainable, safe, and secure ways to move people and goods. Learn more at

About SAFE’s Center for Critical Minerals Strategy (CCMS)
The Ambassador Alfred Hoffman, Jr. Center for Critical Minerals Strategy aims to secure all aspects of the critical minerals supply chain to help ensure the national and economic security of the United States and our allies as we transition from a fossil fuel based economy to a minerals based economy. CCMS is the sole NGO partner for private sector engagement to the State Department through the MINVEST project. The Center is also home to the Sub-Committee on Opportunities and Risks in the Critical Mineral Sector (SCOR) project with Appian Capital.

About SAFE
SAFE is an action-oriented, nonpartisan organization committed to transportation, energy, and supply chain policies that advance the economic and national security of the United States, its partners, and allies. SAFE has convened business and former military leaders since 2004 to support secure, resilient, and sustainable energy solutions. Learn more at