At the US Trade Representative’s (USTR) Section 301 hearing held on May 7 regarding structural excess capacity, American Feed Industry Association (AFIA) Chief Operating Officer Megan Provost cited heavy US import dependence on China for feed-grade vitamins and amino acids and named the European Union and India as alternative suppliers. Whether non-China capacity is sufficient to cover US demand across all the additives in question remains unclear. The alternative-supplier map varies by product, with European producers covering several vitamins, Indian producers covering vitamin B3 and D3, and the broader non-China base for amino acid supply sitting in Southeast Asia and Brazil.
India has zero production capacity in lysine, methionine, threonine, tryptophan, valine, and in vitamins A, B2, and E, according to Expana’s Feed Additives Supply & Demand service. On those eight products, India is a destination market for imports rather than a producer. But India is a meaningful producer in vitamin B3 (niacin and niacinamide) and a smaller producer of vitamin D3, the product Provost specifically cited as 100% China-dependent for the US. Fermenta Biotech operates the entirety of India’s D3 capacity at two sites, accounting for a small single-digit share of global D3 supply behind China and dsm-firmenich Germany. The Indian B3 footprint is materially larger with four producers (Jubilant Ingrevia, Western Drugs, Lasons, and Resonance Specialties) making B3 in the country, making India one of the largest producers.
European production is concentrated in select vitamins. European vitamin A capacity is split across France, Germany, and Switzerland, vitamin E capacity sits in Germany and Switzerland, and vitamin B2 capacity is German. In each, European production runs above regional demand and supports exportable volumes, but the absolute scale is modest. For the structurally Chinese-dominated amino acids such as lysine, threonine, tryptophan, and valine, Europe’s role is limited.
The alternative supplier base for those amino acids sits outside both Europe and India. CJ CheilJedang’s Asia-Pacific footprint, with sites in Indonesia (PT.CJI Pasuruan), Malaysia (Kerteh), and Brazil (Piracicaba), accounts for the largest single non-China supply pillar in tryptophan, valine, and threonine, and a meaningful share in lysine. Indonesia carries the heaviest weight in that footprint, with substantial capacity across all three amino acids and a tryptophan expansion at PT.CJI Pasuruan reported for 2026, the largest single non-China amino acid project in the announced pipeline.
Forward-looking capacity announcements continue with the same pattern. Expana’s Feed Additives Supply & Demand service shows Chinese producers have announced new amino acid capacity through 2028 running roughly an order of magnitude larger than non-China additions, and a comparable gap on the vitamin side. The operative question for any Section 301 remedy is product specific. Vitamins A, B2, and E have European alternatives on a modest scale. Tryptophan, valine, and to a lesser extent lysine and threonine have Asia-Pacific and Brazilian alternatives outside China, primarily through CJ CheilJedang’s regional operations. Vitamin B3 has Indian alternatives. Vitamins B1, B5, and biotin have essentially none.
The statutory remedy menu under Section 301 has three categories, namely additional tariffs or other import restrictions, suspension or withdrawal of trade agreement concessions, and binding agreements with target economies. The most likely combination is country-specific tariffs paired with a product-level exclusion process, mirroring the structure of the original China Section 301 lists. Agricultural groups have already laid the groundwork for the exclusion track in their written comments. The National Pork Producers Council asked USTR to limit remedies to products where excess capacity is immune to market correction and to exempt agricultural inputs. The American Soybean Association and US Soybean Export Council asked for exemptions for critical agricultural inputs. AFIA’s call for calibration points in the same direction. For feed-grade vitamins and amino acids, the exclusion mechanism is the lever most directly tied to the underlying capacity data, particularly for products where non-China capacity is limited.
Post-hearing rebuttal comments closed May 15, and USTR has signaled an intent to be positioned to impose Section 301 remedies by late July, when the Section 122 duties imposed in February are scheduled to expire. Whether USTR can calibrate those remedies to ease US import dependence without disrupting feed-cost stability will depend, product by product, on where alternative supply sits.
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Written by Greg Potter
