Background

Further to SPC(25)66, concerning the USTR’s recently announced modifications and proposed modifications to the Section 301 actions, CSA have provided an initial summary analysis of the modifications, attached as Annex A.

Members are advised to note the proposed clarifications outlined in the Notice and in the CSA report attached, as well as the general comments shared by CSA (many of which have been previously submitted by CSA and ICS to the USTR).

The USTR’s modifications and proposed modifications announced on 10 October are outlined in full in the Federal Register Notice on the USTR website.

As stated in SPC(25)66, members are encouraged to share the anticipated impacts of the above proposed modifications with the ICS Secretariat by 24 October, to inform the ICS’ written feedback to the USTR on these new proposed modifications, which will be submitted by 12 November on the public docket.

As advised by CSA in the report attached, it is expected that any comments on additional areas beyond the proposed modifications, particularly on the ‘clarifications’ which ICS, CSA and many other industry associations have previously requested from the USTR, should also be raised in written feedback submitted on the public docket.

Members are advised to direct any questions or comments to Rachel Noronha, Head of Shipping Policy at Rachel.noronha@ics-shipping.org

SPC(25)67 -Annex A – CSA Analysis USTR Section 301 Modifications 10 October 2025