On July 23, Ambassador Jamieson Greer announced final tariffs, under Section 301 of the Trade Act of 1974 by imposing tariffs on 60 countries/economies for their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. This action comes after the Office of the United States Trade Representative’s (USTR) investigations, which included two rounds of public hearings, more than 2100 public comments, and engagement with our trading partners to remedy these longstanding concerns. The duties take effect on July 24, 2026 (the date on which Section 122 duties expire) for goods entered on or after that time. There is a short grace period through July 28 for shipments already in transit.
The full list of countries/economies is included in the CSMS message from United States Customs and Border Protection. An extra 10% or 12.5% tariff on top of existing duties, varying by country, is outlined in the CSMS message.
To view this CSMS message, click here.
To view the White House memorandum, click here.
To view the pre-publication version of the Federal Register Notice, click here.
To read USTR’s Fact Sheet, click here.
The U.S. Trade Representative has made the following determinations:
• 10 percent is the appropriate rate of Section 301 duties for investigated economies that (i) impose a forced labor import prohibition; (ii) have committed to impose and enforce such a prohibition through an Agreement on Reciprocal Trade; or (iii) have imposed a partial regime with the effect of preventing the importation of certain forced labor goods. These economies are: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom;
• 10 percent or 12.5 percent, net of Most-Favored-Nation (MFN) rate is the appropriate rate of Section 301 duties for certain products of the European Union, Taiwan, Japan, Korea, and Switzerland that are not otherwise exempted, as explained in greater detail in the Federal Register Notice; and
• 12.5 percent is the appropriate rate of Section 301 duty for all other investigated economies, including Brazil and Vietnam.
The U.S. Trade Representative has also determined, in accordance with the specific direction of the President, that product exemptions are appropriate for: (a) raw materials that if subject to these tariffs could lead to the unavailability of domestic supply; (b) products that could cause economy-wide disruptions if subject to these tariffs; (c) products that cannot be grown or produced in sufficient quantities or at reasonable prices in the United States or obtained from other sources; (d) certain products of Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, the European Union, Guatemala, Indonesia, Jordan, Malaysia, Switzerland, Taiwan, or the United Kingdom that would encourage these economies to fulfill commitments regarding forced labor import prohibitions or to enact and effectively enforce a forced labor import prohibition; or (e) articles for which these tariffs may not contribute substantially to the elimination of the acts, policies, and practices of found to be actionable in the investigations.
Some additional notes:
• Steel/aluminum/autos/semiconductors (covered elsewhere), aircraft parts, pharma goods, humanitarian donations, and informational materials will be exempt from this tariff, as they are already covered under other programs or otherwise exempt. There are some additional carve-outs associated with other agreements, such as USMCA and CAFTA-DR.
• The CSMS notice doesn't specifically address how the new Forced-Labor 301 tariffs interact with the existing China 301 tariffs. However, the lack of an explicit exemption suggests the two will be stackable, unless a specific tariff code is otherwise exempted.
Disclaimer: APPA does not make any representations about the completeness, suitability, or adequacy of the information provided during the Office Hours or Trade Talks. Any information provided are intended for general informational purposes only, they do not constitute a recommendation or solicitation to do or omit to do any action and should not be interpreted as legal, regulatory, or compliance advice. You should seek independent advice from qualified professionals before acting on any information provided and/or to evaluate specific regulatory obligations and operational decisions.
Disclaimer from Progressive Trade Consulting: PTC is not a law firm, does not practice law, and does not provide legal advice. The Client should consult legal counsel for any legal matters, including trade compliance. The Importer of Record (IOR) is responsible for complying with customs regulations and managing the import process. This includes obtaining required licenses and permits, classifying and valuing goods correctly, declaring goods accurately, paying duties and taxes, following import rules, and maintaining proper records.