On October 8, 2021, the International Trade Administration (“ITA”) published a request for comments on any subsidies, including stumpage subsidies, provided by certain countries exporting softwood lumber or softwood lumber products to the United States during the period January 1, 2021, through June 30, 2021.

The request is limited to subsidies provided by countries that had exports accounting for at least one percent of total US imports of softwood lumber by quantity, as classified under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 4407.1001, 4407.1100, 4407.1200, 4407.1905, 4407.1906, or 4407.1910, in the first half of 2021.

Official US import data, published by the United States International Trade Commission’s DataWeb, indicate that six countries (Austria, Brazil, Canada, Germany, Romania, and Sweden) exported softwood lumber to the United States during that time in amounts sufficient to account for at least one percent of total U.S. imports.

Parties should include in their comments:

  • the country that provided the subsidy;
  • the name of the subsidy program;
  • a brief description (no more than 3-4 sentences) of the subsidy program; and
  • the government body or authority that provided the subsidy.

Comments are due by November 8, 2021, and must be submitted through regulations.gov, Docket No. ITA-2021-0007. Further information on the comment submission process can be found in the notice. 

The authors acknowledge the assistance of Ryan Orange with this blog post.


Christine Streatfeild is a Partner in the Washington DC Office and on the Steering Committee for the North America Trade Secrets Practice. She focuses on trade remedies and unfair competition cases, including forced labor investigations, antidumping and countervailing duty cases, safeguard measures, duties imposed for national security purposes (Section 232 duties), and Section 337 intellectual property and trade secrets disputes. She appears before the US International Trade Commission (ITC), US Department of Commerce (DOC), and in state and federal courts. Prior to joining Baker McKenzie, Christine served as the acting deputy director of the Generalized System of Preferences (GSP) and in the Environment and Natural Resources division of the Office of the United States Trade Representative. She has also served as an adjunct professor at the Krieger School, Johns Hopkins University, where she taught Global Trade, Policy and Competition. She is also on the 2021 USMCA Dispute Settlement Panels Roster (on behalf of the United States), a position she has held since 2019 (under the NAFTA). Christine focuses her practice on matters related to trade regulatory and intellectual property matters, including economic injury and damages, import duty compliance, and unfair competition allegations.