On April 15, 2026, SAFE’s Center for Strategic Industrial Materials (C-SIM) submitted comments on the United States Trade Representative’s Initiation of Section 301 Investigations: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors.
China has historically engaged in distortionary non-market economic policies in the global metals sector. U.S. allies, many of whom are also the subject of this Section 301 investigation and are an essential part of the defense industrial base, have also been impacted by the distortionary effects of China’s industrial policies. China’s strategic overcapacity, state subsidization, and other non-market practices occur on a scale substantially larger and more consequential than those of other nations and are a global problem that does not just affect the United States.
We encourage both USTR and the Section 301 Committee to prioritize its investigation of China because of the effects of its trade practices, and the opportunity to develop a common response to China’s practices with other allied nations, which would be more complicated if those allied nations were also the subject of the same Section 301 investigation.
As USTR pursues efforts to mitigate structural excess capacity, SAFE’s Center for Strategic Industrial Materials recommends the following: USTR should prioritize investigation of China over other non-market economies and market economies; Tariff actions, should they be pursued, should avoid instances of tariff inversion; USTR should strengthen and modernize Rules of Origin; Meaningful non-tariff action should be seriously explored to mitigate the effects of non-market industrial policies.
Taken together, these policy actions can help restore U.S. leadership in major metals production, a sector that has long been a cornerstone of both economic prosperity and national defense. The challenges are significant, but they are not insurmountable. With coordinated federal leadership and a clear strategic vision, the United States can once again build a resilient and globally competitive industrial base.
Read SAFE’s full comments here.
