IPAA Comment Letter on USTR Section 301

Dear Ambassador Greer:

The Independent Petroleum Association of America (IPAA) writes to recommend a clarification to the definition of “long-term charter agreement” in Annex I to ensure it is reflective of and consistent with customary business practices in the ship chartering industry. …

The proposed clarification to Section 301 Annex I Targeted Coverage is on page 30:

“and is in service and entered into a long-term charter agreement (that is, 20 years or more, inclusive of all extension rights that are at the sole discretion of the charterer) prior to December 31, 2027, will be considered owned and operated by the charterer.”