Computer & Communication Industry Association
PublishedOctober 30, 2025

CCIA Submits List of Digital Trade Barriers for USTR’s Annual Report

Washington — The Computer & Communications Industry Association offered comments to the U.S. Trade Representative in response to its annual request for organizations to outline trade barriers affecting U.S. companies’ ability to access overseas markets. Such filings are one of the primary bases for USTR’s decision on which barriers to include in its annual National Trade Estimates (NTE) report – a country-by-country overview of trade barriers – and set USTR’s enforcement agenda for the year to come.

CCIA’s submission details 516 barriers to digital trade across 61 countries. These include policies that restrict U.S. digital services exports, including asymmetric platform regulations, digital services taxes, data localization requirements, and barriers to the development of AI. This year’s filing also added a focus on newly identified categories of barriers, including obstacles to digital infrastructure such as low-earth orbit satellites and submarine cables, import barriers facing ICT goods and e-commerce, and discriminatory local content quotas and audiovisual service mandates. Given the importance of U.S. digital services exports to the U.S. economy, accounting for US$729.7 billion in exports and a trade balance of US$282 billion in 2024, the continued engagement of the U.S. government on outstanding barriers is critical. CCIA’s 2-pager on the highlights of its NTE filing is here, and an interactive map on digital trade barriers around the world is here.

The following quote can be attributed to CCIA’s Vice President for Digital Trade, Jonathan McHale.

“Our submission details widespread barriers to digital trade–barriers that undermine exports of products and services core to the strength of the U.S. economy and a unique source of surplus in our trade balance. This year’s list shows the continued proliferation of trade barriers, ranging from DMA-style ex ante rules targeting U.S. firms to discriminatory digital services taxes to obstacles to the export of the U.S. AI stack. The Administration made notable progress on addressing many of these issues this year – including the removal of enacted and proposed DSTs in Canada, India, Pakistan, and New Zealand. Commitments made on digital trade between the U.S. and Malaysia, Indonesia, and the EU this year on topics including network usage fees, digital taxes, and local content requirements are encouraging, and we welcome continued focus on outstanding barriers to U.S. digital services exports.”

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