North American Renderers Association (NARA) announced that it has submitted formal comments to the Office of the United States Trade Representative (USTR) and requested to testify in the Section 301 investigation into China’s policies related to excess capacity in manufacturing sectors, including collagen and gelatin.

In its comments, NARA describes a fundamentally imbalanced trade relationship in which US producers are effectively restricted from exporting key ruminant-derived materials to China, while Chinese producers export collagen and gelatin into the United States at prices that undercut market-based suppliers. China continues to prohibit imports of certain U.S. raw materials under outdated restrictions that no longer reflect current science or risk-based trade standards, even as it expands exports to the US market. 

“US producers are locked out of China, while Chinese producers are fully participating in—and distorting — the US market,” said Dana Johnson Downing, NARA’s senior vice president of international programs. “That is not just unfair — it is structurally imbalanced.”

Collagen and gelatin are essential inputs used in food, nutrition, and health-related products, and supply chains are highly regulated, making rapid sourcing shifts difficult. NARA notes that Chinese producers appear to be exporting at prices inconsistent with normal market conditions, contributing to suppressed prices for U.S. producers and reduced value for upstream agricultural inputs such as hides and bones. These conditions discourage investment in domestic and allied supply chains and increase reliance on less transparent imports. 

NARA is urging USTR to take targeted, China-specific action that addresses non-market overcapacity while preserving access to lawful, non-Chinese supply critical to US manufacturers. The association specifically calls for the inclusion of collagen and gelatin in any Section 301 measures, increased scrutiny of transshipment and origin evasion, and coordination across agencies to ensure policies reflect supply chain and regulatory realities. 

NARA cautioned that overly broad measures could disrupt supply chains that are slow to adjust and risk unintended consequences for US downstream industries. A targeted approach, the association emphasized, will better address China-specific distortions while maintaining access to compliant global supply.

Source: North American Renderers Association