The signed RTA doesn’t cover shrimp. Section 301 does investigate it.

The Reciprocal Trade Agreement covers 53% of non-oil exports to the U.S. and liberates 1,673 additional tariff lines, including bananas, cacao, pitahaya, flowers, and fishery products other than shrimp. But on April 28, Section 301 public hearings began, with Ecuador ranked 16th among the 60 economies under investigation for forced labor, subsidies, or environmental dumping. Shrimp (USD 729M in January, +22.2%) is the sector most exposed to that investigation — and the one that falls outside the RTA’s protective umbrella. Section 122, which underpins the temporary 15% tariffs, expires on July 24. The RTA will not be in effect by that date.

Executive Action: Audit the full labor supply chain, including suppliers. Verify whether CNA (shrimp) or AEBE (bananas) filed a formal position. Review compliance clauses in contracts with U.S. buyers. July 24 is the date that does not move.

Why This Matters Now: Section 301 does not require a ruling to cause damage. U.S. buyers react to reputational risk before any verdict is handed down. Shrimp producers with full traceability and clean labor documentation have a structural advantage. Those without it are negotiating from the worst possible position.

What’s New in April: Exporters who did not submit a position to the Office of the U.S. Trade Representative before April 15 missed the first window for defense. The April 28 hearings accepted no further written comments. The next opportunity is the final determination process — with significantly less room to influence the outcome.