Section 301 Investigations: Forced Labor | Sandler, Travis & Rosenberg, P.A.

USTR announced July 23, 2026, that it will impose tariffs of 10% - 12.5% on imports from 60 economies following Section 301 investigations into the measures they have taken to prohibit imports of goods produced with forced labor. The agency said these tariffs will affect 99.4 percent of all U.S. imports.

Lawsuits have been filed challenging these tariffs. Read more here.

Effective Dates

These tariffs become effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on Friday, July 24. Goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. ET on July 24 and entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. ET on July 28 shall not be subject to such additional duty.

Tariff Rates

There is a 10% additional tariff rate on imports from Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan,Sri Lanka, United Kingdom, and Trinidad and Tobago.

There is a 12.5% additional tariff on imports from Algeria, Angola, Australia, Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Hong Kong China, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Turkiye, UAE, Uruguay, Venezuela, and Vietnam.

For products of the European Union (which has 27 member countries) or Taiwan, if the product’s most-favored-nation duty rate is less than 10 percent, a section 301 tariff such that the sum of the two is 10 percent, and if the MFN duty rate is 10 percent or more, a section 301 tariff of zero.

For products of Japan, South Korea, or Switzerland, if the product’s MFN duty rate is less than 12.5 percent, a section 301 tariff such that the sum of the two is 12.5 percent, and if the MFN duty rate is 12.5 percent or more, a section 301 tariff of zero.

Exemptions

Products identified in Annex I and II are exempt from these tariffs. These exceptions include the following.

all articles and parts subject to section 232 tariffs
products of Canada or Mexico that qualify for duty-free entry under the USMCA
textile and apparel articles from CAFTA-DR countries that qualify for duty-free entry under that agreement
listed products of Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, the EU, Guatemala, Indonesia, Jordan, Malaysia, Switzerland, Taiwan, or the U.K. that USTR deems “would encourage these economies to fulfill commitments regarding forced labor import prohibitions or to encourage these economies to enact and effectively enforce a forced labor import prohibition”
informational materials, donations, and accompanied baggage
raw materials that, if subject to the tariffs, could lead to the unavailability of domestic supply
products that could cause economy-wide disruptions if subject to the tariffs
certain products that cannot be grown or produced in sufficient quantities in the U.S. or obtained from other sources
products that, if exempted, would encourage countries to enact and effectively enforce a forced labor import prohibition
articles for which additional tariffs may not contribute substantially to the elimination of the investigated acts, policies, and practices

Textiles and Apparel Quotas

When USTR determines that it is feasible, the agency will establish tariff-rate quotas that, for an initial duration of three years, will allow a certain volume of specific textiles and apparel (based on their imports of U.S. inputs) to be imported from Bangladesh, Cambodia, Indonesia, and Malaysia exempt from the 10 percent Section 301 forced labor tariff. That tariff will be imposed until those TRQs are established.

Background on the Investigations & Findings

On March 12, 2026, the Office of the U.S. Trade Representative initiated Section 301 investigations into the acts, policies, and practices of sixty countries relating to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.

USTR’s report found that the following 54 economies have failed to impose and effectively enforce such a prohibition: Algeria, Angola, Argentina, Australia, the Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, El Salvador, Guatemala, Guyana, Honduras, Hong Kong, China, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, the Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Taiwan, Thailand, Trinidad and Tobago, Türkiye, United Arab Emirates, United Kingdom, Uruguay, Venezuela, and Vietnam.

The report also states that the following six economies have failed to effectively enforce such a prohibition: Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan.