Importers Have Narrow Window to Influence Tariff Outcomes and Seek Exclusions
The Trump administration is rebuilding its tariff wall while simultaneously opening pathways for adjustments, creating a timely opportunity for companies to influence how new measures are applied.
Recent Section 301 actions (covering imports from dozens of countries), and a potential U.S.-China trade mechanism, include time-sensitive comment processes that allow businesses to seek tariff exclusions, reductions, or other favorable treatment for specific products. Companies with affected imports should strongly consider engaging now to ensure their interests are reflected in the final measures.
We recommend taking advantage of this opportunity and reaching out to STR to discuss submitting comments and positioning your products for special consideration. For more information please contact Ned Steiner via email or at (202) 730-4970.
A summary of the actions and key dates are provided below.
Section 301 Forced Labor Proposed Action
On June 2 the Office of the U.S. Trade Representative determined that 60 investigated economies have failed to effectively prohibit imports made with forced labor. In response, USTR is proposing:
- a 10 percent additional tariff on imports from economies that already maintain (or have committed to) forced labor prohibitions, including Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, European Union, Guatemala, Indonesia, Malaysia, Mexico, Pakistan, Taiwan, and the United Kingdom; and
- a 12.5 percent additional tariff on imports from all other covered economies.
USTR is seeking comments on the proposed tariffs, including whether products should be retained or removed, the proposed tariff rates, whether different tariff rates should be applied to certain countries, and the features of a textile mechanism.
Section 301 Brazil Proposed Action
On June 1 USTR determined that Brazil’s acts, policies, and practices on a range of issues are actionable under Section 301. In response, USTR is proposing a 25 percent tariff on all imports from Brazil, with various exemptions.
USTR is seeking comments on the scope of tariff coverage, including the inclusion or removal of particular tariff subheadings.
Section 301 Vietnam IPR Investigation
On May 29 USTR initiated a new Section 301 investigation into Vietnam’s intellectual property practices following its designation as a priority foreign country in USTR’s 2026 Special 301 report.
USTR is inviting comments concerning the issues covered in the investigation and what action, if any, should be taken, including tariff and non-tariff actions.
U.S.-China Board of Trade
On June 2 USTR opened a comment period on the newly-created U.S.-China Board of Trade. Among other things, USTR is seeking input on design of this mechanism, which is intended to manage bilateral trade, as well as the types of non-sensitive products that should be eligible for non-MFN tariff reductions by the U.S. and China.
Key Dates
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REQUEST TO APPEAR
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COMMENTS
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PUBLIC HEARING
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Brazil proposed action
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June 22
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July 1
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July 6
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Vietnam investigation
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N/A
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July 2
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N/A
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Forced labor proposed action
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June 22
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July 6
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July 7
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Board of Trade
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N/A
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July 10
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N/A
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