China WTO Compliance Report

Today, I filed a comment to the USTR regarding China's Compliance with World Trade Organization Commitments, Docket USTR-2025-0015.

September 23, 2025

VIA ELECTRONIC FILING

Mr. Edward Marcus

Chair of the Trade Policy Staff Committee

Office of the United States Trade Representative

600 17th Street NW

Washington, DC 20508

Re: China’s Compliance with World Trade Organization Commitments, Docket Number USTR-2025-0015

Dear Mr. Marcus:

When the People’s Republic of China was allowed into the World Trade Organization (WTO), their entry was sold as the first step toward democratization and full integration with the world economy. Speaking in support of China’s entry in 2000, President Bill Clinton said it would “move China faster and further in the right direction” toward democracy. He further declared that China’s “most important decisions…will be subject to the review of international bodies with rules and binding dispute settlements,” and mocked skeptics who said China would not abide by such decisions. Immediately after China joined, the General Accounting Office found dozens of internal legal changes China would be required to make in order to properly abide by the WTO.

Twenty-five years later, the voices of skeptics have been proven correct. As Ambassador Jamieson Greer said this past July, the “China shock…cost America 5 million jobs after we foolishly allowed China into the WTO.” And those jobs were lost in conjunction with repeated Chinese violations of its WTO agreements. On behalf of the Bull Moose Project, I write to highlight those violations.

In 2021, the Information Technology and Innovation Foundation found that China had failed to live up to “a wide range” of the promises it had made when joining the WTO; these included reducing copyright theft, liberalization of foreign film distribution, and opening access to foreign banks. At the time of entry, China also agreed to join the Government Procurement Agreement, which ensures “open, fair and transparent conditions of competition.” But the PRC dragged their feet on entry, only first half-heartedly attempting to join in 2007. As of 2025, they have still failed to do so.

Dozens of areas GAO highlighted back in 2002, such as Chinese promises to pass laws allowing “transparency, judicial review, uniform enforcement of laws, and nondiscriminatory treatment” have not been fulfilled in any substantial way. At the time, Chinese officials told GAO that they would “strengthen the rule of law” as it related to WTO commitments. But the following two decades revealed that the only law that mattered was the will of the Chinese Communist Party; anything else, including international WTO commitments, were second fiddle at best.

China’s trade issues go beyond a lack of internal action. Indeed, China has been busy: but the actions they have taken have violated the letter and spirit of their WTO commitments. As then-Senator Marco Rubio laid out late last year, violating their WTO commitments was a central aspect of China’s main economic plan – titled “Made in China 2025,” and announced in 2015 – which sought to “heavily subsidized, inexpensive Chinese exports, this time of high-value-added, hightechnology manufactures.”

This is exactly what happened. Examples of heavily subsidized, inexpensive Chinese exports are too numerous to name, but one striking and concerning one is their complete domination of the American civilian drone market, which has only come about through massive state subsidies, a WTO violation. China’s DJI dominates up to 90 percent of America’s drone market. While these drones are used by civilians for personal recordings and play, they are also used by farmers and law enforcement agencies across the country. This is a market which effectively did not exist ten years ago. Now it is booming, and entirely dominated by China.

The drone market is just one of countless concerning examples of Chinese violation of its WTO commitments. China’s non-compliance has spread to practically every supposedly legal export – as well as illegal exports, such as vape pens. China exports thousands to the United States yearly; these are, in the words of Senator Ashley Moody (R-FL), “illegal [and] chemically ridden.” On top of this, their companies flagrantly steal from patented American designs. But China has undertaken effectively no effort to stop these exports. In fact, with the Chinese Communist Party’s total control over Chinese society, it is impossible to imagine that they are not aware of the issue and are, at best, “turning a blind eye” to it – and at worse, are actively trying to poison Americans. 

Fortunately, the Trump administration – as demonstrated by Ambassador Jamieson Greer, Secretary of State Marco Rubio, and of course President Donald Trump himself – is well aware of these violations and are currently involved in high-stakes negotiations with the PRC. We fully support their efforts and urge them to continue holding China accountable in this year’s report and beyond.

Sincerely,

Anthony J. Constantini

Policy Analyst

The Bull Moose Project