The Office of the U.S. Trade Representative (“USTR”) asked the U.S. International Trade Commission (“ITC”) on July 13, 2026, to launch a Section 201 global safeguard investigation into lamb meat imports after domestic sheep producers filed a petition last year with the USTR.

In his letter to the ITC, USTR Jamieson Greer called on the ITC to determine whether foreign lamb meat has been imported “in such increased quantities as to be a substantial cause of serious injury, or the threat thereof, to the domestic industry.” The imports targeted are fresh, chilled, and frozen lamb meat. He added that recent information suggests that lamb meat is significantly undersold in the domestic market and that “firms have exited the domestic industry entirely, and there have been domestic industry job losses, decreased capacity utilization rates, and struggles to maintain profitability.”

On October 31, 2025, the American Sheep Industry Association (“ASI”) petitioned the USTR to request the ITC probe. In a statement lauding USTR’s decision, the group said that it filed the case on behalf of 42 state associations and more than 100,000 U.S. sheep farm and ranches. According to the group, U.S. lamb imports grew nearly 45 percent between 2020 and 2024, capturing “roughly 70 percent of the domestic market … at prices averaging 10.8 percent below domestic product, with some pricing gaps approaching 19.5 percent.”

Under Section 201 of the Trade Act of 1974, the ITC makes injury determinations within 120 days of receiving a request to open an investigation. If an affirmative ruling is found, the ITC must recommend a remedy to the president, such as tariffs or quotas.

Photo of Maryam Mahboob Maryam Mahboob

Maryam is an associate in the firm’s International Trade practice group. She focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues and compliance with U.S. sanctions and export control licensing requirements.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.