Listen to this post

On June 2, 2026, the United States Trade Representative (“USTR”) proposed tariffs under Section 301 of the Trade Act of 1974 (“Section 301”) on imports from 60 countries for their failure to enforce prohibitions related to forced labor. The USTR found that these failures are unreasonable and burden U.S. commerce. The proposed tariffs range from 10% to 12.5%, though they do contain several carveouts.

Among the 60 investigated economies, the USTR found that 54 countries failed to impose and effectively enforce a prohibition on the importation of goods produced with forced labor, while the USTR found that the remaining six (6) economies had implemented but failed to enforce a forced labor prohibition.

The USTR is proposing 10% tariffs on the following 14 countries, which the USTR found either have a forced labor prohibition in place or have pledged to take action relating to goods made with forced labor as part of their specific trade agreements reached with the United States:

  • The European Union (“EU”), Canada, Ecuador, Indonesia, Mexico, Pakistan, United Kingdom (“UK”), Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, and Taiwan.

The USTR proposes 12.5% tariffs on the remaining 46 countries, which are:

  • Algeria, Angola, Australia, the Bahamas, Bahrain, Brazil, Chile, China, People’s Republic of, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Honduras, Hong Kong, China, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, the Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Thailand, Trinidad and Tobago, Turkey, United Arab Emirates, Uruguay, Venezuela, and Vietnam.

Under the USTR’s proposed actions, the following articles will not be subject to the proposed Section 301 tariffs, which can be found in Annex A of the USTR’s Federal Register notice:

  • Goods that qualify under the United States-Mexico-Canada Agreement (“USMCA”);
  • Goods that qualify for duty-free treatment under the Dominican Republic-Central America Free Trade Agreement (“CAFTA-DR”) from Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua.
  • Certain fruits, vegetables, and spices;
  • Certain chemicals, minerals, and ores;
  • Goods related to the aerospace and semi-conductor industries; and
  • Certain metals classified in Harmonized Tariff Schedule of the United States (“HTSUS”) chapters 80 and 81.

The USTR’s announcement can be found here, and a copy of the USTR’s full report is here. This finding follows the Section 301 investigation initiated by the USTR on March 12, 2026, which we covered here.

The USTR’s Section 301 Committee will hold public hearings concerning the proposed actions on July 7, 2026.  Requests to appear at the hearings along with a summary of proposed testimony must be submitted by June 22, 2026.  The public may also submit written comments by July 6, 2026 to the public docket. Per the USTR’s Federal Register notice, the USTR seeks comments regarding the following:

  • The specific products to be subject to increased duties, including whether products should be retained or removed from the scope of the action, or whether products currently listed in Annex A should be added to the scope of the action;
  • Whether products listed in Annex A are appropriately excluded;
  • The level of the increase, if any, in the rate of duty;
  • Whether different tariff rates should be applied to an economy where the economy has made a commitment to the United States to impose and enforce a forced labor import prohibition; has imposed a forced labor import prohibition; or has imposed a partial regime with the effect of preventing the importation of certain forced labor goods; and
  • Features of a textile mechanism, including the U.S. and foreign products to be covered, the relative market opportunities for each side, and the tariff rate (if any) to be applied to products subject to that mechanism, as well as whether a similar mechanism should apply to any other product or sector.

Please contact a member of Husch Blackwell’s International Trade and Supply Chain team should you wish to submit comments as soon as possible in order to provide sufficient time to prepare and submit comments prior to July 6, 2026.

The Husch Blackwell International Trade and Supply Chain team will continue to monitor and provide updates on this investigation as they become available. If you have company specific questions or concerns, please contact your Husch Blackwell attorney.