Yesterday, the United States Trade Representative (USTR) took the first step towards implementing new 301 tariffs.
In this regard, USTR determined that additional tariffs were warranted in response to the “acts, policies, and practices” of countries that have not effectively imposed and enforced a prohibition on the importation of goods produced with forced labor. USTR found the actions of those countries is unreasonable, burdens or restricts U.S. commerce, and are thus actionable under Section 301(b) of the Trade Act.
As a result, the USTR has proposed the following additional tariffs.
- A 10% tariff on products from the following that either currently impose (but have failed to effectively enforce), or have undertaken commitments to impose, a prohibition on the importation of forced labor goods: the EU, the UK, Argentina, Bangladesh, Canada, Cambodia, Ecuador, El Salvador, Guatemala, Indonesia, Malaysia, Mexico, Pakistan and Taiwan;
- A 12.5% tariff on products from the remaining countries under investigation, including Brazil, Chile, Costa Rica, Egypt, India, Thailand, and Vietnam. For a complete list of affected countries, please contact us.
It is expected, however, that these tariffs will not be apply to either USMCA-qualifying importations or on apparel eligible for entry under DR- CAFTA.
Comments this proposal are due July 6, 2026, and USTR will hold hearings about the proposed actions in these investigations on July 7, 2026. Those interested in testifying must advice USTR by June 22, 2026.
We strongly recommend that clients who will be impacted by these tariffs consider filing comments. We are available to assist with this process as needed.
For further information, please contact Gail Cumins at gcumins@spcblaw.com, Alli Baron at abaron@spcblaw.com or call us at 212-425-0055.
