Recently, the Office of the United States Trade Representative (USTR) issued a public notice announcing that it has completed Section 301 investigations into 60 economies and proposed corresponding measures. The investigation focused on whether the relevant economies have established and effectively enforced systems prohibiting the import of products made with forced labor.
According to the notice, the USTR found that certain economies have failed to adequately prohibit or effectively enforce bans on imports of forced labor products, thereby imposing a burden on U.S. commerce. This constitutes an actionable matter under Section 301 of the U.S. Trade Act of 1974.
The core of the proposed measures is the imposition of additional Section 301 tariffs on imported goods from the investigated economies. The notice specifies:
A proposed 10% additional tariff for economies that have established relevant bans, made related commitments, or have partial systems in place;
A proposed 12.5% additional tariff for all other economies;
Certain products may be excluded based on the Annex A exemption list;
A special mechanism may be established separately for textile and apparel products.
Important Note: This measure is currently in the "public comment and hearing" phase and has not yet officially taken effect.
According to the USTR schedule, interested parties may apply to participate in the public hearing by June 22, 2026. The deadline for submitting written comments is July 6, 2026, and the hearing is scheduled for July 7, 2026. Whether the measure will be officially implemented, its effective date, specific tariff rates, and exemption scope remain subject to the USTR's final announcement.
For Chinese enterprises exporting to the United States, this policy sends a clear signal: the U.S. is further integrating "forced labor compliance" into its trade tariff and import enforcement systems. In addition to conventional tariffs, Section 301 tariffs, anti-dumping and countervailing duties (AD/CVD), and Section 232 tariffs, enterprises will need to place greater emphasis on supply chain compliance, origin authenticity, traceability of production materials, and completeness of import declaration documents.
Enterprises exporting to the U.S. in the near term are advised to focus on the following matters:
Timely confirm whether their product HTS codes may be included in the exemption list;
Assess the potential impact of additional Section 301 tariff costs;
Prepare compliance documentation in advance regarding supply chains, manufacturers, and raw material sources;
Avoid undervaluation, misdeclaration, incorrect classification, and origin circumvention;
Strengthen document review for sensitive categories such as textiles, apparel, photovoltaics, agricultural products, chemicals, and consumer goods.
Overall, this measure is not yet a final implementation rule. However, if it is subsequently enacted, it may increase tariff costs and compliance review pressures for some Chinese products exported to the U.S. Exporters, importers, and customs clearance enterprises are advised to continue monitoring subsequent USTR announcements and make advance preparations for pricing, tax calculations, and customs clearance compliance.
6 Economies Proposed for 10% Additional Section 301 Tariffs
Canada, Ecuador, European Union, Indonesia, Mexico, Pakistan
54 Economies Proposed for 12.5% Additional Section 301 Tariffs
Algeria, Angola, Argentina, Australia, Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Chile, China (including the mainland, Hong Kong SAR, and Taiwan region), Colombia, Costa Rica, Dominican Republic, Egypt, El Salvador, Guatemala, Guyana, Honduras, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Republic of Korea, Sri Lanka, Switzerland, Thailand, Trinidad and Tobago, Turkey, United Arab Emirates, United Kingdom, Uruguay, Venezuela, Vietnam
