Silverado Submits Comments: Section 301 Investigation on Structural Excess Capacity

Silverado is encouraged by the initiation of these Section 301 investigations to address and ideally remedy effects generated by certain economies’ creation and maintenance of structural excess capacity in critical sectors. We focus our comments on spotlighting certain of the acts, policies, and practices of the People’s Republic of China (“China” or “PRC”) that burden or restrict U.S. commerce. We further focus on sectors that are critical to the U.S. industrial base and essential security interests, including semiconductors, their inputs, and downstream products in which they are embedded; plus industrial emissions intensive, trade-exposed goods, including steel and aluminum. For those metals, we address how lax or inadequate environmental protection in China confers competitive advantage to Chinese producers and how those advantages burden or restrict U.S. companies in both U.S. domestic and global markets. We close with policy recommendations specific to lax or inadequate environmental protections so that these investigations may remedy burdens and restrictions to U.S. producers caused by China’s and certain other countries’ regulatory arbitrage.