The North American Renderers Association (NARA) has submitted formal comments to the Office of the United States Trade Representative and requested to testify in the Section 301 investigation into China's policies related to excess manufacturing capacity, including collagen and gelatin.
In its comments, NARA describes a trade relationship in which U.S. producers are effectively restricted from exporting key ruminant-derived materials to China, while Chinese producers export collagen and gelatin into the U.S. at prices that undercut market-based suppliers. China continues to prohibit imports of certain U.S. raw materials under restrictions that NARA says no longer reflect current science or risk-based trade standards.
"U.S. producers are locked out of China, while Chinese producers are fully participating in — and distorting — the U.S. 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 used in food, nutrition and health-related products. NARA notes that highly regulated supply chains make rapid sourcing shifts difficult. The association says Chinese producers appear to be exporting at prices inconsistent with normal market conditions, suppressing prices for U.S. producers and reducing value for upstream agricultural inputs such as hides and bones. NARA contends these conditions discourage investment in domestic 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 non-Chinese supply. The association specifically calls for inclusion of collagen and gelatin in any Section 301 measures, increased scrutiny of transshipment and origin evasion, and cross-agency coordination to ensure policies reflect supply chain and regulatory realities.
NARA cautioned that overly broad measures could disrupt supply chains that are slow to adjust. A targeted approach, the association said, would better address China-specific market distortions while maintaining access to compliant global supply.
