Last week, the Office of the United States Trade Representative (“USTR”) closed the public comment period in two of its Section 301 investigations examining:
(1) Forced Labor: The failure of certain trading partners to prohibit and effectively enforce bans on imports produced with forced labor, which provides foreign producers with an artificial cost advantage that distorts competition in the U.S. market; and
(2) Excess Capacity: Structural excess capacity and production in key sectors, where foreign government interventions have supported production “untethered from the incentives of domestic and global demand,” leading to overproduction, persistent trade surpluses, and the displacement of U.S. production.
The investigations focus on whether these acts, policies, and practices are “unreasonable or discriminatory” and burden or restrict U.S. commerce. USTR’s initiation notice for the excess capacity investigation specifically identified “processed food and beverages” among the sectors “plagued by excess capacity and production,” noting resulting “loss of domestic production capacity.”
The Southern Shrimp Alliance, together with the American Shrimp Processors Association, submitted joint comments in both investigations on behalf of the U.S. shrimp industry. These submissions demonstrated that foreign governments’ acts, policies, and practices are “unreasonable” under Section 301 with respect to both (1) the failure to prohibit forced labor in upstream supply chains and (2) subsidy-driven excess capacity in aquaculture and seafood processing. The submissions explained how these unfair practices harm the U.S. shrimp industry by suppressing prices, displacing domestic production, and reducing market share, output, employment, and investment.
SSA also submitted comments as part of the Real American Food Producers Alliance, a coalition of U.S. food producers (including the American Honey Producers Association, Catfish Farmers of America, Crawfish Processors Alliance, and the Louisiana Farm Bureau) raising concerns in the Section 301 investigation regarding excess capacity about increased U.S. dependence on foreign sources of food and the erosion of domestic food production. This submission described how foreign government interventions support production well beyond market demand, contributing to sustained oversupply, declining prices, and the United States’ increased reliance on imports across key food sectors.
A broad range of U.S. food producers outside of the shrimp industry similarly used the comment period to highlight the growing impact of these dynamics on domestic food production. Submissions from industries including fruit and vegetable processors, rice, seafood, specialty crop producers, and sugar described a consistent pattern of foreign government intervention driving excess capacity, suppressing prices, increasing import penetration in the U.S. market, and displacing U.S. food production.
- Citrus: California citrus producers, through the California Citrus Quality Council, California Citrus Research Board, and California Citrus Mutual, reported that government-supported industrial policies in countries such as Peru, Chile, Argentina, and South Africa have contributed to rising imports into the United States, including an increase in Argentine lemon imports from approximately 18,000 metric tons to 94,000 metric tons between initial market access and 2024, more than five times the original projection. These imports have undercut California lemon growers’ prices and continue to displace domestic production, including reduced retail shelf space for California mandarins as shipments from foreign producers expand before and after the domestic growing season.
- Catfish (fish fillet): The American Coalition for Fair Trade in Seafood reported that government-supported expansion of Vietnam’s aquaculture industry has resulted in substantial excess capacity, with Vietnam accounting for 42 percent of global fish fillet production in 2024 and exporting over 90 percent of its output. In addition, Vietnam produced approximately 3 billion pounds of freshwater catfish (pangasius) in 2024, with production reported to have increased by 11 percent in 2025. These exports have contributed to the displacement of domestic producers despite existing trade remedies, as Vietnam’s fish fillet exports to the United States totaled approximately $306 million in 2025, representing a significant share of the U.S. market.
- Crawfish: U.S. crawfish producers, through a submission by the Louisiana Farm Bureau Federation, reported that imports entering the United States at prices below fair market value have contributed to declining import prices, including a drop in landed duty-paid values from $5.64 per pound (2013-2018) to $3.02 per pound (2019-2024), levels well below U.S. production costs, which exceed $9.00 per pound for crawfish tail meat. These declining prices have been accompanied by increasing import penetration, with frozen whole-boiled crawfish rising to over 37 percent of total U.S. imports, and continued market concentration, with China accounting for approximately 70 percent of U.S. crawfish imports. As a result, U.S. crawfish producers report operating below capacity and facing continued downward pressure on prices.
- Fruit and Vegetables: The American Fruit and Vegetable Coalition reported that foreign government support across the full supply chain has enabled sustained export capacity and low-priced imports into the United States from China, the European Union, Mexico, and Thailand. Most critically, China supplied over 237 million kilograms of prepared or preserved vegetables in 2025, accounting for more than half of total U.S. imports under that category and representing an approximately 80 percent increase from 2019 levels. The submission identified 21 U.S. fruit and vegetable processing facility closures since 2018, pointing to a pattern of declining domestic output, price suppression, and reduced investment in the U.S. processing sector.
- Honey: The American Honey Producers Association reported that export-oriented production in countries, specifically India and Vietnam, has expanded beyond domestic demand, contributing to rising imports into the United States, including a 565 percent increase since 1990 and a decline in domestic market share from over 70 percent to less than 19 percent. India and Vietnam accounted for nearly 46 percent of U.S. honey imports in 2025, while imported honey consistently enters the U.S. market at prices below domestic production costs. This contributed to a 41.7 percent decline in U.S. honey production since 1990, a 25 percent reduction in managed colonies, and sustained financial losses, including a 22.7 percent operating loss rate.
- Processed Peaches: The U.S. processed peach industry, through the California Cling Peach Board and California Canning Peach Association, reported that long-standing subsidies and export-targeting policies in China and the European Union have supported sustained production and export volumes, contributing to rising imports into the United States, including a 68 percent increase in imports from the EU between 2020 and 2025 and annual imports from China exceeding 40,000 metric tons over the same period. These imports have been sold at prices consistently below U.S. production costs and have contributed to a nearly 90 percent decline in U.S. export volumes since 2005 and a roughly 60 percent decline in domestic deliveries from growers to processors.
- Processed Pears: The U.S. processed pear industry, through the Northwest Horticultural Council, Pacific Northwest Canned Pear Service, Washington Oregon Canning Pear Association, California Pear Advisory Board, and California Pear Growers Association, reported that China’s export-targeting policies and subsidies have supported sustained canned pear production and low-priced exports, contributing to continued import volumes into the United States, including shipments of over 20,000 metric tons annually between 2020 and 2025, and pricing levels roughly half those of U.S. products. These imports have contributed to a 23 percent decline in U.S. canned pear production between 2021 and 2025. Notably, this contraction has left only two remaining U.S. processors and resulted in the loss of grower contracts and the removal of hundreds of acres of pear orchards.
- Rice: U.S. rice producers, through submissions from the USA Rice Federation and the U.S. Rice Producers Association, reported that government support programs in countries such as India and Thailand expand production beyond market demand and contribute to rising imports into the United States, including a doubling of imports over the past decade to $1.5 billion (1.51 million metric tons) in 2025. These submissions further report that import volumes in 2025 were equivalent to more than 600,000 acres of U.S. production, and that approximately 200,000 acres were lost from U.S. rice production between 2024 and 2025, with an additional 470,000-acre decline in long-grain planting projected for 2026.
- Scallops: U.S. scallop fishermen, through a submission by the Fisheries Survival Fund, reported that government-supported expansion of Japan’s scallop industry has contributed to increasing export capacity and rising shipments to the United States, including imports increasing from 1.4 million kilograms in 2018 to 8.9 million kilograms in 2024, making Japan the largest source of U.S. scallop imports since 2022. By 2024, U.S. imports of scallops accounted for more than a quarter of Japan’s total scallop exports. The loss of Japan’s traditional export markets also led to a “freefall” in scallop prices, contributing to downward pressure on U.S. prices and significant economic harm to U.S. fishermen.
- Groundfish: The Oregon Trawl Commission reported that China’s subsidy-driven expansion of its seafood processing sector has created substantial excess capacity, including approximately 30.2 million metric tons of annual processing capacity across 9,433 facilities, accounting for roughly 35 to 40 percent of global seafood processing as of 2025. These practices have been associated with declining economic performance in U.S. fisheries, including a 44 percent decrease in revenue for Oregon groundfish vessels from $29.6 million in 2017 to $16.7 million in 2023 and a 41 percent decline in profit per pound over the same period.
- Sugar: The American Sugar Alliance reported structural excess capacity in global sugar markets, resulting in rising volumes of low-priced imports into the United States, including a 333 percent increase in over-quota imports from 194,013 to 840,667 metric tons between 2021 and 2025. Imports from El Salvador and Honduras alone increased by more than 2,900 percent and 2,500 percent, respectively, over that period. These imports have diminished domestic production capacity, including a 16.8 percent decline in sugarbeet farms between 2012 and 2022 and a 13.6 percent decline in beet processing facilities over the past decade.
- Table Grapes: The California Table Grape Commission reported that government-supported export expansion in Peru, Chile, and Mexico has resulted in sustained excess capacity and rising shipments to the United States, including exports increasing by more than 600 percent over six seasons and Peru and Chile accounting for approximately 45 percent and 35 percent of total U.S. imports, respectively. These imports have displaced domestic production, reducing the U.S. market share of domestic table grapes to approximately 40 percent, and contributed to oversupply conditions, including shipments of 3.4 million boxes per week during the 2025-2026 season and sharp price declines of $2 to $4 per box from levels above $40 per box in December 2025.
- Wine Grapes: U.S. winegrape growers and wine industry participants, through submissions from organizations including the California Association of Winegrape Growers, the Lodi Winegrape Commission, Allied Grape Growers, and others, reported that foreign government support in the European Union has sustained structural excess capacity in global wine markets contributing to measurable contraction in domestic production. California winegrape output has declined from approximately 4.28 million tons in 2018 to roughly 2.62 million tons in 2025, a reduction of nearly 40 percent, alongside declining domestic market share and rising import share. Growers also reported widespread vineyard removals, unharvested crops, and declining returns, including instances of hundreds of thousands of tons of grapes left unharvested and farm-level price declines of more than 40 percent.
In sum, submissions to the USTR from a broad array of domestic food producers catalogue how import competition is quickly eroding America’s capacity to feed itself. Absent meaningful action under Section 301 that addresses structural excess capacity in foreign food production, imports will continue to displace domestic food production and increase U.S. reliance on imports for critical food products.
The testimony of these American food producers poses a fundamental question to President Trump’s Administration: Are we, as a country, better off by continuing to offshore food production? For those who value consumption of low-priced products regardless of circumstances, the answer is yes. However, for those who understand the costs of reliance on foreign supply chains to rural communities across the country and the vulnerabilities created by sourcing food products overseas, the reports of these varied, ostensibly unrelated industries should be deeply concerning.
Review the joint submission of the American Shrimp Processors Association and Southern Shrimp Alliance to the USTR in the Section 301 investigation on forced labor here: https://shrimpalliance.com/wp-content/uploads/2026/04/Shrimp-Industry-Narrative-Excerpt-USTR-2026-0133-00126678-CAT-14655-Public-Document.pdf
Review the joint submission of the American Shrimp Processors Association and Southern Shrimp Alliance to the USTR in the Section 301 investigation on structural excess capacity here: https://shrimpalliance.com/wp-content/uploads/2026/04/SSA-And-ASPA-USTR-2026-0067-00126406-CAT-14354-Public-Document.pdf
Review the submission of the Real American Food Producers Alliance to the USTR in the Section 301 investigation on structural excess capacity here: https://shrimpalliance.com/wp-content/uploads/2026/04/Real-American-Food-Producers-USTR-2026-0067-00127102-CAT-15096-Public-Document.pdf