221s are countered by basic infantry with small arms fire and AT nade.
The 222 is no longer infantry viable as is largely useless against anything exceot further M3s.
Guard also effectively counter it.
FHTs are problematic due to retreat dmg, as are all flame affects.
AT nade it to reduce its speed, and focus on map control.
Guard are effective vs it, especiakly when crippled by an AT nade,
Fast tech to T70 will counter it, but will probably result in a fast PIV inncurrent meta, afterwhich you will be hard pressed to get a T34 or Su85. Map and especially fuel control is essential for this tech route.
Personally I recommend going for a ZiS instead, and Maxims to maintain map control.
Cheaper and more efficient mine use is also something to consider in preventing FHTs from overruning your positions, particularly in conjunction with ZiS. You can afford the mines, since Ost sunk 120 muni into the flamer upgrade.
Thank you for your input nullist but i do have a few things to comment on.
Firstly you said the 221 are countered by basic infantry, i find this slightly incorrect, when i play ostheer i normaly grab a 221 and use it like i use an M3, i keep it at max range out of range from AT nades and if you keep away from the nade you will win against 1 squad of cons. if you micro better than him and he retreats to late you can run the squad down, i have done it many times.
I like the idea of field guns, problem is they normaly get a halftrack AFTER they have seen an M3 and normally dealt with it, which leaves me with 2 options. grab a zis and delay my tanks by ALOT, or rush t70 which locks me into t3 and grants me practically NO AT, no field guns and only the t34's main gun, while that deals with the FHT it just goes poof vs anything bigger.
I guess the bottom line is, a smart German will counter your build, and if he can deal with the M3's or T70'sreliably (the only things that is extremly strong imo) they will out counter you and suddenly you cant do anything. soviets biggist weakness is it's lack of versatile units. The only good thing for them apart from the above units is the mines
I truly believe if the m3 and t70 get nerfed and nothing else happens, soviets will be unable to win vs an equally skilled german.