USTR Significant Foreign Trade Barriers 2025: i2Coalition Comments

Each year, the Office of the United States Trade Representative (USTR), through the Trade Policy Staff Committee (TPSC), publishes the National Trade Estimate Report on Foreign Trade Barriers (NTE Report). In preparation for this report, the USTR seeks information about the scope and nature of current significant trade barriers and distortions. The Internet Infrastructure Coalition (i2Coalition) exists to help those who build and operate global Internet infrastructure fight against those very threats—including the rising implementation of‬‭ Internet shutdowns, global site-blocking regimes, and efforts to block virtual private networks‬‭ (VPNs). We submitted comments to the USTR highlighting the harmful impacts of these significant and growing trade barriers. 

The i2Coalition is urging the USTR to address the growing threat of global Internet shutdowns and network-blocking regimes, which are creating significant barriers to trade, especially for U.S. small and medium-sized technology businesses. In our public filing, we highlight how these restrictions disrupt the free flow of information, harm economic growth, and threaten the global Internet’s openness and accessibility.

Our comments call out in particular the damaging long-term implications of DNS resolver blocking for small-and medium-sized businesses and the end users who interact with them:

While governments may seek to justify DNS blocking as necessary for immediate national‬ ‭ security, public safety, or other law enforcement reasons, the long-term trade implications are‬ ‭ vast. U.S. services are left vulnerable to inconsistent, non-transparent enforcement actions that‬ ‭ lack international cooperation, putting them at a disadvantage in foreign markets. U.S. firms‬ ‭ face economic harm from reduced access to consumers, lost advertising revenue, and‬ ‭ operational disruptions, further amplified in markets where alternative services are controlled or‬ ‭ heavily influenced by state actors.‬ “

We invite you to read our full comments to better understand what’s at stake:

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Please join us in advocating for policies that protect digital trade, encourage innovation, and ensure a unified, open global Internet.

About the i2Coalition

The Internet Infrastructure Coalition (“i2Coalition”) ensures that those who build the infrastructure of the Internet have a voice in public policy. With more than 100 member brands, we are a leading voice for web hosting companies, data centers, domain registrars and registries, cloud infrastructure providers, managed services providers, and related tech. We protect innovation and the continued growth of the Internet’s infrastructure which is essential to the global economy. 

For more in-depth updates on Internet policy, including issues that impact your Internet infrastructure organization, please contact us about joining the i2Coalition.