Letters to Washington
| November 12, 2025

Letter to USTR on Modifications and Proposed Modifications of Section 301 Action on China's Targeting of the Maritime, Logistics and Shipbuilding Sectors

The National Stone, Sand & Gravel Association (NSSGA) and the National Asphalt Pavement Association (NAPA) appreciate the opportunity to comment on the United States Trade Representative’s proposed modifications to the Section 301 action announced on October 10, 2025. These comments follow our joint submission on March 24, 2025, which expressed concern about imposing fees on Chinese-built vessels, and the NSSGA comments submitted on November 7 regarding the underlying suspension of the Section 301 action. The new proposal would remove Targeted Coverage Article VII, effectively eliminating the exemption for laker vessels serving the Great Lakes. This change would have direct and negative consequences for the aggregates and asphalt sectors. NSSGA members include stone, sand, and gravel producers; industrial sand suppliers; along with equipment manufacturers and service providers who support them. With over 9,000 locations, the aggregates industry produces about 2.5 billion tons of materials each year in the United States. Aggregates are the building blocks of modern society and are vital for constructing and maintaining heavy infrastructure such as roads, railways, bridges, tunnels, data centers, warehouses, residential buildings, water supply systems, sewers, electrical grids, and telecommunications networks.